Juntunen v. Carlton CountyAnnotate this Case
The Supreme Court affirmed the ruling of Workers' Compensation Court of Appeals (WCCA) that Respondent was entitled to workers' compensation benefits, holding that Respondent was not entitled to relief on his claims on appeal.
A licensed psychologist diagnosed Respondent, a former deputy sheriff for Carlton County, with post-traumatic stress disorder (PTSD). A compensation judge ruled that Respondent was not entitled to workers' compensation benefits because a subsequent psychological evaluation requested by the County resulted in a diagnosis of major depressive disorder but not PTSD. The WCCA reversed, holding (1) under Minn. Stat. 176.011, subd. 15(e), deputy sheriffs are entitled to a presumption that PTSD is an occupational disease if they present a diagnosis of PTSD, regardless of whether their employer offers a competing diagnosis; and (2) Respondent was entitled to the benefit of the presumption that he had a compensable occupational disease, and the County failed to rebut the presumption.