Tea vs. Ramsey County
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The case revolves around a social worker, Janine Tea, who claimed to have developed post-traumatic stress disorder (PTSD) due to her exposure to the details of a murder committed by one of her clients. The county initially provided workers’ compensation benefits to Tea but discontinued those benefits after a licensed psychiatrist concluded she did not have PTSD. Tea objected to the discontinuance of her benefits and underwent an independent psychological evaluation in which she was diagnosed with PTSD. The compensation judge determined that Tea has compensable PTSD.
The Workers’ Compensation Court of Appeals (WCCA) affirmed the compensation judge's decision. The county appealed, arguing that Tea did not meet the diagnostic criteria for PTSD listed in the Diagnostic and Statistical Manual of Mental Disorders (DSM).
The Supreme Court of Minnesota affirmed the WCCA's decision. The court held that the WCCA’s affirmance of the compensation judge’s finding that Tea has compensable PTSD is not manifestly contrary to the evidence. The court also held that the WCCA did not err in refusing to use the DSM to re-evaluate the compensation judge’s factual finding that Tea has PTSD. The court clarified that compensation judges may review the DSM criteria when considering the persuasiveness of expert reports, but judges may not use those criteria to make their own diagnosis of a claimant’s condition.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
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