Brian Ganley v. Upper Darby Township (Workers' Compensation Appeal Board)

Summary

The Pennsylvania Commonwealth Court reviewed a workers’ compensation claim by a firefighter who developed PTSD after unsuccessfully performing CPR on two infants who died. The court held that whether the events constituted abnormal working conditions was a legal question subject to de novo review, and it reversed the Workers’ Compensation Appeal Board’s order denying benefits. The opinion emphasizes the fact-sensitive nature of psychological-injury claims under Pennsylvania’s Workers’ Compensation Act.

Holdings

1. The facts found by the Workers' Compensation Judge established an extraordinarily unusual and distressing combination of events that constituted an abnormal working condition as a matter of law.
2. The Board erred as a matter of law by failing to conclude that the facts found by the Workers' Compensation Judge established an abnormal working condition.

Questions Presented

1. Whether the unsuccessful performance of CPR on two infants and witnessing their deaths within a 16-month period constituted an abnormal working condition for a firefighter under Pennsylvania workers' compensation law.
2. Whether the Workers' Compensation Judge and Board erred as a matter of law in treating the individual components of the events—performing CPR, responding to emergencies, and witnessing death—as normal working conditions rather than evaluating the combined circumstances.
3. Whether the Board's decision was consistent with the humanitarian purposes of the Workers' Compensation Act.

Disposition

reversed_and_remanded