McCrone v. Bank One Corp.

Summary

The Ohio Supreme Court held that psychological or psychiatric conditions not arising from a compensable physical injury or occupational disease are excluded from workers’ compensation coverage under R.C. 4123.01(C)(1). The court rejected an equal-protection challenge to that statutory exclusion, concluding that it is rationally related to legitimate governmental interests, including preserving the workers’ compensation fund and addressing proof concerns. The court reversed the appellate court’s finding of unconstitutionality and remanded the cause.

Holdings

1. Psychological or psychiatric conditions that do not arise from a compensable physical injury or occupational disease are excluded from the definition of injury and from workers' compensation coverage.
2. R.C. 4123.01(C)(1) does not violate the Equal Protection Clauses of the United States or Ohio Constitutions because requiring a physical injury or occupational disease is rationally related to legitimate governmental interests.

Questions Presented

1. Whether R.C. 4123.01(C)(1) excludes psychological or psychiatric conditions that do not arise from a compensable physical injury or occupational disease from workers' compensation coverage.
2. Whether R.C. 4123.01(C)(1)'s exclusion of such psychological or psychiatric conditions violates the Equal Protection Clauses of the United States and Ohio Constitutions.

Disposition

reversed_and_remanded