March 21, 2023
MN Supreme Court decision clarifies the nature and extent of PTSD claims in the state
By Aaron Schmidt, Defense Counsel with Lynn, Scharfenberg and Hollick
The Minnesota Supreme Court issued the long-awaited opinion of Chrz v. Mower County and Minn. Counties Intergovernmental Trust on March 8, 2023.
Ryan Chrz was a Deputy Sheriff in Mower County, Minnesota, who had been diagnosed in 2019 with work-related PTSD, major depression and moderate to severe alcohol disorder, after witnessing several traumatic events at work. In May of 2020, he filed a claim petition requesting workers’ compensation benefits.
An independent medical exam of Chrz was requested in December 2020 by his employer and insurer, and that doctor opined that Chrz did not meet the criteria for PTSD under Minn. Stat. Section 176.66, subd. 1.
The following March, he was examined again by his treating doctor, who concluded that his condition had improved. As a result, Chrz’s treating doctor changed his diagnosis from PTSD to “other specified trauma and stress related disorder” caused by work.
The matter went to hearing in June 2021, and the compensation judge found that Chrz had sustained work-related PTSD and awarded him ongoing payment of wage loss. She further held that his treating doctor had diagnosed PTSD from April 2019 through March 2021, but that from March 2021 forward, Chrz no longer had PTSD. However, Chrz had argued that despite a diagnosis change, he remained disabled from a mental illness.
The employer and insurer appealed, and the Workers’ Compensation Court of Appeals (WCCA) reversed the compensation judge’s decision, stating that Chrz was no longer entitled to ongoing benefits because he no longer met the criteria for having a personal injury under Minnesota workers’ compensation law.
Chrz appealed to the Minnesota Supreme Court, which affirmed the WCCA, holding that an employee is not entitled to workers’ compensation benefits under Minn. Stat. Section 176.66, subd. 1, when the employee no longer has a diagnosis of PTSD by a licensed professional using the most recent edition of the Diagnostic and Statistical Manual of Mental Disorders as required by Statute.
This opinion provides clarity in defining the nature and extent of PTSD claims in Minnesota, and a definitive interpretation in limiting the narrow application of Minn. Stat. Section 176.011.
This is not intended to serve as legal advice for individual fact-specific legal cases or as a legal basis for your employment practices.