At Schotter Millican, we stand for workers' rights, particularly in challenging cases like Anderson v. City of Yonkers, which has become a critical case in the landscape of workers' compensation law in New York. This case explores whether workers exposed to high-risk environments during the COVID-19 pandemic can seek compensation for mental stress, even if they did not contract the virus. Below, we explain the key takeaways from this case and how it affects essential workers across various industries.
Background: Essential Workers and COVID-19 Stress
During the height of the COVID-19 pandemic, essential workers—including healthcare professionals, teachers, and transportation workers—faced significant mental stress while continuing their jobs in person. While many workers had the option to work remotely, essential workers had to navigate heightened risks daily. Although much attention was given to the physical danger of contracting COVID-19, Anderson v. City of Yonkers highlights the mental toll experienced by those who were in constant proximity to the virus without getting infected.
Workers' Compensation Law and COVID-19
New York workers' compensation law allows claims for work-related injuries, which can include contracting COVID-19 on the job. However, the law has been less clear regarding mental stress claims caused by fear and anxiety about exposure to the virus.
- COVID-19 as a Work-Related Accident:
When workers catch COVID-19 at work, it is typically treated as an “accident,” not an “occupational disease.” This means that they don’t need extensive medical evidence to prove where they contracted it, especially if they worked in environments with public exposure, like hospitals or schools. - Mental Stress Without Physical Injury:
Anderson's case questioned whether mental stress from working in a high-risk environment (without contracting the virus) should also be compensable. For example, teachers and healthcare workers often had heightened anxiety due to daily exposure to COVID-19-positive individuals.
Mental Stress Claims Under New York Law
New York workers' compensation law treats mental stress injuries similarly to physical injuries. In Anderson v. City of Yonkers, the courts explored the following points regarding mental stress:
- Mental Stress vs. Physical Injuries:
Both mental and physical injuries can qualify for compensation under workers' compensation law. However, the worker must prove that the stress they experienced was greater than what is normal for their profession. Anderson, for example, worked in a high-risk COVID-19 environment and argued that the stress was beyond the typical expectations for her job. - The “Similarly Situated Worker” Standard:
To qualify for compensation, the stress experienced by the worker must be more severe than what similar workers faced. The case raised questions about what is “normal” for essential workers during an extraordinary event like the COVID-19 pandemic. Anderson argued that COVID-19 made her work environment uniquely stressful, especially due to her underlying health condition (asthma).
Key Legal Rulings in Anderson v. City of Yonkers
The court initially ruled against Anderson and other workers who claimed mental stress during COVID-19. The reasoning was that working in a COVID-19-positive environment had become “normal” for essential workers during the pandemic. However, Anderson’s legal team successfully appealed, arguing that mental stress claims should be judged by the same standards as physical injuries. Key developments include:
- Mental Stress and Pre-existing Vulnerabilities:
Workers with pre-existing health conditions, like asthma or other vulnerabilities, may face more stress in dangerous environments. Anderson's vulnerability to respiratory illness made her stress claim more compelling. - Reversal of Initial Decision (2024):
In March 2024, the court reversed its earlier decisions, establishing that mental stress injuries caused by exposure to COVID-19 could be treated the same as physical injuries. This ruling allowed Anderson to move forward with her claim for mental stress resulting from the extreme risk of teaching in person during the pandemic.
Implications for Workers: Protecting Your Mental Health
The ruling in Anderson v. City of Yonkers has broad implications for workers in New York and beyond:
- A Path for Mental Stress Claims:
Workers no longer need to meet a higher standard for mental stress injuries compared to physical injuries. This decision opens the door for more workers to claim compensation for mental harm caused by dangerous or highly stressful work environments. - Special Consideration for Vulnerabilities:
If you have pre-existing conditions or other vulnerabilities that make you more susceptible to stress or harm, this can strengthen your claim for compensation. - Pandemic Work Conditions:
The court recognized that the COVID-19 pandemic created a new work environment where what was once considered "normal" had changed, making certain stressors extraordinary and therefore compensable.
Conclusion: Schotter Millican Fights for Your Rights
At Schotter Millican, we understand that mental health is just as important as physical health when it comes to workplace injuries. The Anderson v. City of Yonkers ruling reinforces this notion, providing essential workers and others exposed to extreme stress with an avenue for compensation. If you or someone you know has suffered mental stress due to dangerous working conditions, particularly during the COVID-19 pandemic, contact us today. Our team will work tirelessly to protect your rights and help you receive the compensation you deserve.