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UNDERSTANDING
THE WORKERS’ COMPENSATION SYSTEM IN NEW JERSEY
CONTENTS:
If the employer becomes aware of a work-related accident after 30 days but before 90 days, the employee must show that his failure to notify was due to a reasonable excuse such as fraud, mistake, ignorance of the law, or some other justifiable circumstance. An illiterate employee would find it easier to justify such a mistake than would a lawyer or paralegal employed by a large law firm specializing in workers' compensation defense. In cases of occupational disease, the employee must notify the employer within five months after she ceased being exposed to the occupational disease, or within 90 days after she knew or should have known the nature of her disability and its relation to her employment, whichever is later. Failure to give notice within this these time frames will bar all compensation. Notice provisions differ from statutes of limitations, which prohibit the filing of lawsuits after specified times. The statute of limitations in cases of workers' compensation is two years after the accident or, in cases of occupational disease, two years after the claimant first knew the nature of her disability and its relation to her employment. An employee who notifies her employer of an injury or occupational disease at the earliest possible time will nevertheless be precluded from bringing a claim if she waits more than two years to file a lawsuit.
The policy behind the workers' compensation system is to compensate regardless of fault. Whereas a plaintiff in a personal injury case must prove the negligence of the defendant, a worker injured on the job may receive benefits without having to prove his employer failed to exercise due care. The New Jersey Legislature, in passing the workers compensation laws, decided it would be unfair and counterproductive to deny benefits to a negligent worker performing his job in good faith.2 Take, for instance, a salesman in the office who, mistakenly thinking his chair is behind him, attempts to sit but falls to the ground and suffers a herniated disc. It makes no difference that this may be his own fault. Under the workers' compensation system, where fault is not in issue, he is entitled to medical treatment, temporary disability benefits, and permanent disability benefits. The Legislature believed that a system that litigates fault would be overburdened with proceedings to determine who is negligent and who is not. As an administrative system, the workers' compensation system also differs from the civil tort system in the way cases are tried. Personal injury cases are tried in Superior Court, where formal rules of evidence govern the proceeding. Hence at a workers' compensation trial the hearsay rules3 do not apply and documents can be authenticated and introduced with less formality. Workers' compensation cases are tried by judges, instead of by juries as is the case with most personal injury claims that reach trial. The relative informality of workers' compensation trials, however, should not lull potential claimants into thinking they will escape unpleasant matters such as attacks on credibility which are often made by aggressive defense attorneys. The best response to such an assault is a well-prepared witness with claims thoroughly supported by medical and other evidence.
Injured workers are also entitled to temporary disability benefits,4 which provide 70% of the employee's average weekly wage up to a limit,5 and permanent disability benefits, which compensate for diminished ability to work or complete disability with respect to job performance. Employers who refuse to provide temporary disability benefits can be forced to do so by a Motion for Temporary Disability. Like Motions for Medical Care, these Motions must be heard within 30 days of filing. Employers who deny medical treatment and/or temporary disability benefits will often do so on, among other reasons, the following grounds:
It can take years to resolve a workers' compensation claim where the injury is serious. Injured workers need medical treatment; and the more serious the injury, the more involved and prolonged the treatment will be. A worker continues to be entitled to medical treatment as long as it is curative (likely to improve his condition) or relieves the worker of the effects of the injury. But once the worker returns to work, even if he has not reached maximum recovery, temporary disability benefits cease. For the worker with a serious back injury, treatment might include physical therapy lasting for months. If such therapy fails to help, epidural injections may be the next course of treatment. And if this too fails, surgery might be necessary. The period of recuperation following surgery typically includes additional physical therapy, which again can last for months. While the employee remains unable to work during curative treatment, he may collect temporary disability benefits at 70% of his weekly earnings. The Workers' Compensation Statute provides for the payment of temporary disability benefits for up to 400 weeks (7.7 years).7 Though it is rare that payments or treatment last this long, treatment can and often does take a substantial time. Sometimes the insurance company may be reluctant to provide additional treatment if an initial course of treatment fails. If this should occur, a Motion for Medical Treatment and (if also necessary) Temporary Benefits will have to be filed. This will further delay a final resolution of the case, but for a good cause: to provide needed assistance to the worker.
If the worker's skills are limited, and his job imposes significant physical demands, the worker's attorney should advise the examining physician to evaluate the worker in light of these circumstances. A computer programmer with a severe leg injury will be less disabled than a floor tile installer with the same injury who possesses a limited education. The floor tile installer has to use his legs more to perform his job than a programmer who sits in a chair for most of the day. And if the tile installer's injury prevents him from performing manual labor in the future, he will find it much more difficult to get an office job than the computer programmer or some other college-educated worker. Of course, if the programmer injures a hand or wrist, or is afflicted by carpal tunnel syndrome, her ability to earn a living may be affected in a way comparable to a floor tile installer with an identical injury. Unless instructed otherwise, Petitioners' examining doctors often fail to note factors such as the nature of the Petitioner's job, and the Petitioner's level of skill, which is relevant to ability to earn a living in other fields if a Petitioner is totally disabled in a given occupation. In addition, where the worker has limited skill and job options, his attorney must stress these factors to the insurance company and the judge as well. The Respondent will also send the worker to an examining doctor or doctors. These doctors conduct examinations and set forth numbers representing estimates of the worker's disability. Doctors used by the employer will always give an estimate lower than the estimate provided by the worker's doctors. For instance, in the case of an unoperated herniated disc with minor nerve impingement, the worker's orthopedic expert may fix the worker's disability at 45% of partial/total disability.8 The employer's orthopedic specialist may find a partial/total disability of 5%. Ultimately the case will, in all probability, be resolved at a figure in between these two estimates. The numbers used by examining doctors refer to charts published yearly by the New Jersey Division of Workers' Compensation. These charts assign dollar values to percentages of disability ranging form 1% to 100%. In the example just used, if the accident occurred in the year 2000,9 5% of partial/total disability translates in dollars to $4,530.00, and 45% of partial/total disability translates to $92,000.10 Different rates apply to different categories of injuries. A back injury is classified as "partial/total." This classification mandates a greater figure in dollars for any given percentage of disability than, for example, an injury to an arm or a leg. Whereas an award of 20% of partial/total is worth $19,536.00, an award of 20% partial disability for a leg is worth $9,513.00; 20% for a hand is worth $7,399.00; and for an ear, $1,812.00. Medical examinations to determine permanent disability may not be undertaken until 6 months (26 weeks) after the employee's authorized medical treatment ends, or 6 months from the date the employee returns to work, whichever is earlier. This delay is built into the system to insure that the employee's condition remains permanent and stationary before any final determinations as to permanent disability are made. After all examinations are finished, the parties meet in court for a pretrial—a discussion and negotiation session between the attorneys, held in the judge's chambers. The worker's attorney should know if the defense is ready to discuss settlement, in which case the worker will be asked to appear in court to approve or reject settlement offers. If an agreement is reached, the worker will take the witness stand to indicate he understands and approves of the settlement. If the parties cannot settle the case, it will be set for trial.
Where there is a previous injury to the same body part, a determination of permanent disability will include a deduction or "credit" for the prior injury. For instance, a Petitioner hurt her right shoulder 1994 and settled the case for 10% of partial/total in 1997—a settlement of $7,380.00.12 Then, in 1998, she reinjured her shoulder. In 2000, the parties agree she is disabled 20% of partial/total. The monetary value of a 20% settlement for partial/total disability in 1998 is $17,796. From this figure, however, the defense will get a credit of 10% of partial/total in 1998 dollars: $8,280.00, not $7,380.00, the value of the settlement in 1994. Thus the value of the settlement, before deductions for attorney fees and Petitioner's examinations, will be $17,796.00 minus 8,280.00, or $9,516.00. If a prior disability and a current disability combine to render the worker totally disabled, an application may be made to a state fund known as the Second Injury Fund, which pays that percentage of disability benefits not attributable to the most recent employer. In setting up this fund, the Legislature wished to promote the hiring of partially disabled workers. The Second Injury Fund furthers this policy by preventing the employer from having to pay full disability benefits if a partially disabled worker suffers a totally disabling injury.
The judge has discretion in awarding attorney fees. Typically a Petitioner's attorney is awarded a fee of 20% of the value of the settlement. However, the judge usually apportions the fee, and might, for instance, require the Respondent to pay 60% of the fee, leaving 40% for the Petitioner. In the example of the right shoulder injury discussed above, an attorney fee of 20% of $9,516.00 equals $1,903.20. From this figure, assuming the apportionment ratio is 60% to 40%, the Respondent would pay 1,141.92 and the remainder, $761.28, would be taken from the Petitioner's settlement. Fees are also awarded to the Petitioner's examining physicians. Again the judge has discretion to award fees, which often in the case of doctors are apportioned equally between the parties. So if the court awards an orthopedic doctor $200.00 for an exam, the Respondent will pay $100.00 and $100.00 will be taken from the Petitioner's settlement. The Petitioner never has to pay for the Respondent's exams or for authorized or necessary medical treatment. A small fee may also be taken from the worker's settlement to compensate an interpreter, should one be needed. Continuing with our example, if we assume that an interpreter is not required to put the settlement on record, the Petitioner would ultimately receive $8,294.72 ($9516.00 minus $761.28 minus $100.00). Within 5 weeks after the settlement is put on record, the Respondent should send a check to the Petitioner's attorney, who will distribute the settlement money.
Some settlements are for cash only and leave the worker with no right to reopen a case should his condition worsen or should additional treatment become necessary. These settlements, known as Section 20 Settlements,14 cover situations where a genuine dispute exists over issues such as liability and causation. A liability issue, for instance, might arise if the employer has a basis to claim that the employee was not at work when the injury occurred. And a causation dispute could arise if the employer has grounds to assert that a previous injury is causing the employee's present symptoms. A worker's attorney should never agree to a Section 20 settlement where there is no genuine dispute over the worker's ability to prove his case. Otherwise the worker will be left without recourse to additional medical treatment and benefits if his condition worsens.
Each additional dependent increases the amount of benefits paid by 5%, up to a maximum of 70% of the worker's weekly wages. Thus, if the surviving spouse in the example above had two minor children with the deceased worker, the amount of total death benefits paid would be 60% of the worker's wages, or $360.00 per week, to be apportioned among three dependents. As with temporary disability benefits, though, death benefits are subject to a maximum weekly rate of 75% of the state average weekly wage. The state average weekly wage in the year 2000 is $757.08; and 75% of this totals $568.00. So if a deceased worker earned a weekly wage of $1500.00, his dependents, however many may exist, would be paid no more than a total of $568.00. Notes: 1.
Seriously injured workers, whether they have a third-party claim or
not, should also consider applying for Social Security, and, if
applicable, a Disability Retirement. They should be aware, however,
that the employer's insurance carrier will be entitled to certain
offsets or credits for recoveries or benefits obtained outside of
the workers compensation system.
WORKERS’ COMPENSATION STRESS CLAIMS AS A REMEDY FOR WORKPLACE BULLYING[1] Introduction
The workers’ compensation system is currently the main venue offering a legal remedy for workplace bullying that does constitute discrimination based on race, age, sex and other protected categories under New Jersey and federal law. Under workers’ compensation law, benefits are provided for work-related injuries. If the bullying does not result in an injury requiring medical treatment, though, there is no remedy. In many cases, however, bulling in the workplace results in stress-related health problems. According the U.S. Workplace Bullying Survey of 2007, the health of 45% of targets is affected.[2]
Bullying, as defined by The Workplace Bullying Institute, is repeated mistreatment manifested as either (1) verbal abuse; or (2) conduct which is threatening, humiliating, or intimidating; or (3) sabotage that interferes with work; or (4) some combination of the above.[3]
Three Necessary Elements of a Stress Claim
1. Proof of objectively stressful work conditions which the worker reacts to in a stressful manner. In Goyden v. State Judiciary, 256 N.J. Super 438 (App. Div. (1991), aff’d. 128 N.J. 54 (1992), the Court found that there was a mere subjectively perceived conflict with a supervisor which did not rise to the level of a compensable psychiatric claim. Goyden alleged that he was subjected to vindictive management procedures, particularly a biased and defamatory work evaluation that resulted in major depressive disorder, which compelled him to retire. The court, however, found that the criticism was merited. Goyden also alleged he was stressed by uncontrollable backlog and staff shortages, but the court found that these were not the cause of his stress. The Court noted, though, that work conditions such as backlog and staff shortages are subject to objective verification and thus could form a basis for a stress claim. Id. at 456.
Williams v. Western Electric Company, 178 N.J. Super. 571 (App. Div. 1981). makes clear that an employee’s subjective reaction is not to be disregarded, though it cannot be the sole ingredient of the formula for compensation. Williams also teaches that objectively verifiable work conditions need not be outside of the ordinary work stresses: “The requirements of unusual strain or stress as a causative factor was rejected [. . . ] and we, as an intermediate court, cannot revive that approach.” Id. at 106. Thus Williams specifically rejected the Wisconsin rule, which requires proof that the psychiatric injury must result from “greater dimensions than the day-to-day mental stress and tensions which all employees must experience.” Id.
Walck v. Johns Manville, 56 NJ 522 (1970), involved a reaction to mental stress resulting in a heart attack. The petitioner feared he may lose his job, but this fear was unfounded. After the retirement of his long-time supervisor, the petitioner claimed, he became nervous, tense, and insecure about his work performance and about his ability to hold his job under his new supervisor. But the court found that his anxiety was purely subjective and based on an unfounded imaginary worry as opposed to a reasonable basis in fact. Therefore the court found that where the employee is a worrier who becomes unnecessarily nervous about losing his job and this worry results in a heart attack, it is not compensable.
In Williams v. Western Electric, supra, the petitioner alleged that his work on an assembly aggravated his underlying schizophrenia. However the court found that he had a purely subjective reaction to his job because of his schizophrenia: his diseased mind reacted to merely normal work demands. Therefore compensation benefits were denied.
2. Work conditions peculiar to the workplace (not just common to everyone). Fiore v. Consolidated Freightway, 140 N.J. 452, 468-470 (1994) illustrates “peculiar to the workplace”:
If an employee contracted pneumonia as a result of working in a freezer as a packer, the condition would be a compensable occupational disease because it would be due to a cause which is peculiar to the employment. If the same employee contracted pneumonia as a result of incidental exposure to a fellow employee with pneumonia, however, this might not be compensable because the condition may not be due to a condition characteristic or peculiar to the employment.
Goyden held that merited criticism by a supervisor is common to all occupations and is therefore not peculiar to any particular trade or occupation. Id. at 451. In Williams, the petitioner had preexisting schizophrenia and evidence indicated he was equally irritated by things and people on and off the job. The facts in psychiatric claims brought before the Division must be distinguished from Goyden and Williams.
Cairnes v. City of East Orange held that a layoff or unemployment is not a risk arising out of employment but rather out of the economy and economic forces. A layoff notice is a threat that confronts every worker[4] and is therefore not stress peculiar to the workplace.
3. Objective medical evidence showing that the work conditions were the material cause of the psychiatric disability. Professional analysis in psychiatric claims, as opposed to physical claims, depends upon “analysis of the subjective statement of the patient.” Saunderlin v. E.I. Dupont Company, 102 N.J. 402, 412 (1986). Though subjective evidence requires analysis beyond mere subjective statements and will not be present when the physician simply “parrots” the patient’s complaints, objective evidence of a physical manifestation is not required in psychiatric claims. Id. at 412, 416. The distinction between objective and subjective “is not between physical and mental (or body and mind) but between independent professional analysis and the bare statement of the patient.” Interposition of a professional judgment between a subjective statement and an award of disability does not involve exclusion of the subjective statement: any medical examination “must begin with the [patient’s] subjective statement.” In physical disability claims, medical analysis often goes beyond subjective statements by virtue of clinical and laboratory tests. But in psychiatric claims, diagnostic criteria include descriptions of states of mind “discoverable only through” the subjective statement. Id. at 412-414. Under Saunderlin, Reasoned analysis of the subjective statement of a psychiatric patient is objective within the meaning of N.J.S.A. 34:15-36. Id. at 313-314. But where petitioners saw their psychiatrists only once upon recommendation of their attorneys and the psychiatric reports merely dressed the complaints in “psychiatric nomenclature,” the claims for psychiatric disability were dismissed. Id. at 418-419.
Specific Event versus Occupational Stress
In Prettyman v. State of New Jersey, 298 N.J. Super 580, 594 (App. Div. 1997), the court stated that Walck and Williams do not apply when an alleged psychiatric disability is caused by a specific event rather than a stressful work environment. Wrongly suspected of stealing from a coworker, petitioner was removed from work by the State Police and taken to a station for aggressive questioning. The court applied the “but for” test to determine that the petitioner’s injuries arose out of her employment: but for the fact that she came to be suspected of theft while carrying out her usual duties, she would not have been taken for questioning a few days later. Respondent’s contention, based on Cairns, that police investigations of theft are as normal to the workplace as layoff notices, was rejected along with the argument that the interrogation was a separate event that did not arise “during the course of employment.” Among other things, the court's distinction in Prettyman between a specific event and a stressful environment suggests that a worker’s predisposition cannot be used to bar specific event claims. Hence the court noted that the “employer takes the employee as the employer finds the employee, with all of the pre-existing diseases and infirmiti[es].” Evidence of the petitioner’s emotional and excitable nature, precluded by the trial judge, was not deemed significant to respondent’s defense. Id. at 592-595.
Limits to psychiatric stress claims apply to fact-specific circumstances and, in some cases such as Cairns, are based on considerations of public policy. These limits, however, do not apply to psychiatric injuries arising from accidents or occupational diseases that have caused other injuries, such as, for example, a machinist depressed after losing an arm or a construction worker depressed due to occupational pulmonary disease. A psychiatric claim in these latter instances would be limited only by Saunderlin, supra, which requires reasoned, objective, professional psychiatric analysis of the patient’s state of mind.
Burden of Proof in Occupational Claims
In Lindquist v. City of Jersey City Fire Department, 175 N.J. 244 (2003), a firefighter with history of smoking cigarettes established that his exposure to smoke from fires contributed in a material way to his lung disease. Lindquist clarifies the standard applicable to all occupational claims in a way favorable to petitioners.
Standard of Proof: “It is sufficient in New Jersey to prove that the exposure to a risk or danger in the workplace was in fact a contributing cause of the injury. That means proof that the work related activities probably caused or contributed to the employee’s disabling injury as a matter of medical fact. Direct causation is not required; proof establishing that the exposure caused the activation, acceleration or exacerbation of disabling symptoms is sufficient.”
Bargain Theory: The Workers’ Compensation Act “involved a historic trade-off whereby employees relinquished their rights to pursue common-law remedies in exchange for automatic entitlement to certain, but reduced, benefits whenever they suffered injuries . . . “ At the “ heart of this ‘original bargain . . . . is the notion that the burden of proof on claimants would be easier . . . under workers’ compensation laws than under common law.”
As this standard applies to occupational claims in general, it would govern occupational stress claims and the related sub-category of occupational bullying claims.
3 Types of Workers’ Compensation Benefits
1. Medical Treatment (Controlled by the Employer). Employee cannot go to his own doctor without getting prior authorization from the carrier—risks personal responsibility for payment in some instances. But the employer’s right to control treatment may be lost if the treatment offered is ineffective or unreasonable. Benson v. Coca Cola, 115 N.J. Super 585 (Law. Div. 1971). See also N.J.S.A. 34: 15-15 providing that if the employer fails to provide treatment the employee may obtain it but the employee must request the treatment. A letter should be sent to the comp carrier or employer’s attorney demanding adequate treatment.
Cure and Relieve. N.J.S.A. 34:15-15 requires an employer to furnish treatment “necessary to cure and relieve the worker of the effects of the injury and to restore the functions of the [worker’s] injured member or organ where such restoration is possible.” But Hanrahan v. Township of Sparta, 284 N.J. Super 427, 436 (App. Div. 1995), held that the phrase “cure and relieve” is not conjunctive: treatment must be provided as long as competent medical testimony establishes treatment is necessary to either cure the worker or relieve the worker of symptoms.
2. Temporary Disability Benefits (“TDB”). Paid weekly (for up to 400 weeks or 7.7 years) at 70% of average weekly wages up to a maximum in 2008 of $742 (SAWW 989.23 x .75). 34:15-12(b) and 34:15-38. Paid until the worker may resume her job or until MMI (is as far restored as the permanent character of the injuries will permit), whichever occurs first. Monaco v. Albert Maund, 17 N.J. Super. 425, 431 (App. Div. 1952).
Restricted Duty: Harbatuk v. S&S Furniture Systems Insulation, 211 N.J. Super 614, 628-629 (App. Div. 1986). If the employer provides full-time restricted employment within the worker’s capacity, temporary disability benefits may be stopped, but not if the employer fails to offer suitable work. Furthermore Harbatuk favorably described an Oregon decision supporting the principal that a worker need not seek easier work in a different field while under active treatment to cure a work-related medical condition.
Med-Temp Motions: Must be filed if a worker has no way of obtaining necessary medical treatment, if there is a dispute over restricted duty, or if the worker is in financial distress and has no other means of obtaining temporary disability benefits. The motion is given priority on the calendar.
Temporary Disability Benefits (TDB). A disabled P can get TDB for six months (at 66.6%) while waiting for resolution of Med-Temp. Motion (fill out Agreement to Repay form). The Department of Labor gets a lien on comp recovery that must be repaid if the comp case is successful.
3. Permanent Disability Benefits. Worker not eligible until 26 weeks (6 months) after MMI or after return to work—whichever is earlier. Must show by objective medical evidence that the worker suffered a loss of functional capacity to work. The award is not for pain and suffering though pain and suffering may be considered if it affects ability to function. Both sides must have permanency exams to resolve the case. Benefits may be for permanent partial total (the worker is not fully disabled) or permanent total (due to injury the worker is unemployable in a reasonable stable job market).
Questions
You can get medical and temporary disability benefits without being entitled to permanent disability benefits, but usually once medical attention is required, there will be some finding of permanency.
Certainly once your health is affected, if not before. However you should go to management immediately and ask for help. Psychiatric damages are compounded when management fails to properly respond and thus effectively becomes complicit in the bullying. Ask your employer to provide medical treatment if you feel upset or depressed, and report bullying immediately.
E-mail, diary (note physical symptoms of stress—weight loss, upset stomach, vomiting, etc.), doctor visits (to company doctors and/or private doctors), e-mail to supervisors, etc.
You can but certainly keep a duplicate copy; or send by certified mail RRR.
You never can be sure; it can be tough for colleagues to take action perceived to be against their employer. Nevertheless, corroboration is very helpful in bullying cases as well as in other stress claims. Such proof can come not only through coworkers, supervisors, personnel department staff, but also from therapists, family doctors, and family members. E-mail makes good evidence; supportive letters from coworkers also are helpful.
Jobs are always at risk in these circumstances. You must weigh your health against financial needs if you can’t work it out with the assistance of management. Look for written company policies. Most written policies have complaint procedures for harassment (usually gender or racial) but you may want to pursue the same procedures for bullying. You may go out of work and collect temporary disability benefits with doctor’s certification. Psychiatrically injured workers may also be able to obtain a doctor note specifying work accommodations and thus seek protection under the Americans with Disabilities Act or NJ equivalent.
[1] This article is a slight reworking of notes I prepared for presentation at “Bullying in the Workplace,” a conference on November 22, 2008 sponsored by New Jersey State Bar Foundation and the Organization of Chinese Americans. [2] http://bullyinginstitute.org/zogby2007/WBIsurvey2007.pdf [3] http://bullyinginstitute.org/education/bbstudies/def.html [4] In American Motors Insurance Company v. L-C-A Sales Company, 155 N.J. 29, 38 (1998) the New Jersey Supreme Court noted that Cairns was “based largely on ‘the underlying policy considerations rather than the clear language of the act,’” quoting Cairns at 399. American Motors Insurance Company addresses the question of third-party coverage for an employer sued civilly for violating the Law Against Discrimination. Observing that Cairns involves a general economic risk applicable to all employment, the Court distinguished the situation in Cairns from one where an “employee-specific layoff notice” illegitimately targets an individual. Though American Motors Insurance Company does not address a workers’ compensation claim, its reasoning nevertheless suggests that a layoff notice targeting a specific employee may create a right to compensation benefits if an illegitimate or illegal purpose is involved. Cairnes v. City of East Orange, however, held that a layoff or unemployment is not a risk arising out of employment but rather out of the economy and economic forces. A layoff notice is a threat that confronts every worker.
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