Court of Appeals Affirms Denial of Death Benefits Based on Mental Health Claim

 Jackson v. Bridgestone Americas Tire Operations, No. 21-0017 (Iowa App. Dec. 15, 2021)

Claimant's estate alleged that he committed suicide as a result of a mental injury arising out of his employment.  The agency and district court denied benefits.  

Claimant was a 28 year employee at Bridgestone and he missed only three days of work in those 28 years.  In August of 2016, claimant engaged in acts of insubordination (disobeying supervisory directives concerning safety and quality) and lying about those acts.  He was suspended for a cooling off period.  He was subsequently called into a meeting and was told he was being fired.  Claimant went home and was found in the garage with his vehicle running.  At that point, he agreed to come out, but he left the home and was found dead by hanging a few hours later.  Claimant had made statements at the time that he would take his life if he lost his job.

Approximately eight months before his death, claimant was diagnosed with major depressive disorder and anxiety disorder.  In the initial consult, claimant said he hated various individuals, including his wife, son, neighbor and a dentist, but not anyone from his place of work.  Claimant attended some psychotherapy, but declined a referral for psychiatric treatment.  

Following claimant's death, Dr. Gallagher issued an opinion finding that claimant's death was related to his employment.  The deputy disagreed, finding that the condition was rooting in personal issues outside of employment.  The commissioner affirmed, as did the district court.  

The court notes that for a mental/mental injury, both legal and medical causation must be demonstrated.  To show legal causation, the claimant must show workplace stress of greater magnitude than the day to day mental stresses experienced by other workers.  The court finds that the issue of factual causation was waived because no legal authority was presented to support claimant's position on this issue.  The court addressed the issue in terms of substantial evidence.  The court found there was substantial evidence supporting the decision of the agency.  Specifically, the court found that Dr. Gallagher's opinion did not consider important evidence, specifically claimant's insubordination and the fact that the company policy mandated termination for such actions.  Thus, the agency was within its authority to provide little weight to Dr. Gallagher's opinion.  On the legal causation issue, the court noted that there was no evidence presented that the stress experienced by claimant was greater than that of similarly situated employees who had been insubordinate and were terminated.  Claimant was found not to have met his burden on the issue of legal causation.  The decision of the agency was affirmed.