Missouri Court Rules Second Injury Fund Not Responsible for Worker’s Mental Injury

The Missouri Court of Appeals upheld a ruling that the Second Injury Fund is not liable for a worker’s permanent total disability benefits stemming from a psychological injury. The worker, employed by WireCo World Group for 28 years, injured her shoulder in 2015 and later claimed that she developed diabetes, hypertension, anxiety, and depression as a result. These conditions were initially linked to a car accident and her mother’s death but were later associated with her work injury.

After settling her shoulder injury claim with WireCo in 2018, the worker underwent a psychological evaluation. The evaluator attributed her depression to the physically demanding nature of her job. Despite this, an administrative law judge, the Labor and Industrial Relations Commission, and the Missouri Court of Appeals all determined that the worker did not provide sufficient evidence to hold the Second Injury Fund liable for her psychological injuries.

The court emphasized that her psychological issues predated the 2015 injury and were influenced by several factors, including her mother’s death and her voluntary layoff, rather than her work injury. Additionally, the court noted the absence of any substantial psychiatric treatment or change in medication after the 2015 injury. The timing of the post-settlement evidence further weakened her claim, as there was no indication of a psychological work injury related specifically to the 2015 incident.