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Stress caused by breaking up jail fights doesn't warrant extra disability payments for guards, court rules

The Supreme Judicial Court ruled today a state law intended to financially help jail guards injured by inmates only applies to physical injuries, not mental ones.

The ruling comes in the case of a Suffolk County corrections guard who sued to get benefits after the Suffolk County Sheriff's Department stopped paying him workers' comp for the racing heart, heavy breathing and light headedness he experienced after he broke up a series of inmate fights in 2010.

The state's highest court ruled that because the law specifies "bodily injury," it means only physical injuries, such as "any burn, fracture of any bone, subdural hematoma, injury to any internal organ," which rules out symptoms caused by stress, such as those experienced by the guard. The court noted the guard underwent two independent medical exams, and that:

Both doctors concurred that the defendant's symptoms were a physiological response to stress, that the sinus tachycardia was neither the result nor the cause of any physical harm, and that there was no evidence of structural heart disease. ... As the plaintiff's sinus tachycardia is an impairment of function which has not led to structural heart damage, it is not a physical impairment or injury. Therefore, the plaintiff does not have a bodily injury within the meaning of the statute.

The court concluded that had the legislature intended to include mental distress, it would have used the phrase "personal injury" or even just "injury."

Personal injury, as the term is used in the workers' compensation statute, encompasses physical as well as mental or emotional disabilities. ... As G. L. c. 126, § 18A, expressly refers to the workers' compensation statute, we must assume that the Legislature used the narrower term intentionally.

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