Tea v. Ramsey County et al.

Tea v. Ramsey County et al., No. A23-1207 (Minn. Supreme Ct., April 17, 2024)   

Please see our previous case summary for background information in this case. This matter was appealed to the Minnesota Supreme Court.

On appeal, the Minnesota Supreme Court considered (1) whether WCCA’s affirmance of the compensation judge’s factual finding that employee has compensable PTSD is manifestly contrary to the evidence and (2) whether WCCA made an error of law by refusing to itself use the DSM to re-evaluate the compensation judge’s factual finding that employee has PTSD.

With respect to the first issue, the Minnesota Supreme Court emphasized that the compensation judge determined that Dr. Keller’s report was more persuasive than Dr. Gratzer’s report. They also emphasized that neither party questioned the foundation of the reports. The Supreme Court further noted that a different compensation judge could have reached a different conclusion. However, they did not identify anything in the records that was “clearly requires reasonable minds to adopt a contrary conclusion.” As such, they affirmed the WCCA’s finding that the compensation judge’s finding was not manifestly contrary to the evidence.

As it pertains to the second issue, employer argued that the WCCA’s refusal to consider that the facts did not conform to the DSM description of PTSD was an error of law. Specifically, employer noted that Minn. Stat. § 176.011, Subd. 15(d), requires a PTSD diagnosis to be based on the DSM description. As such, it was the employer’s argument that the WCCA was required to analyze whether the facts here show that employee met the DSM diagnostic criteria. The Supreme Court disagreed.

The Supreme Court emphasized that in Smith v. Carver County, they reversed a WCCA decision that would have required compensation judges to independently read and apply the DSM-5. Employer argued that this case was distinguishable from Smith; however, the Supreme Court was not persuaded. In the alternative, employer argued that Smith should be overturned and that the compensation judges and the WCCA could make their own DSM diagnoses in PTSD cases. Again, the Supreme Court was not persuaded and noted that “judges are applying the law—not diagnosing patients.” Again, they emphasized as they did in Smith, “the DSM is a guideline for medical and health professionals, not a checklist for judges.”  As such, the Supreme Court found no reason to overturn Smith or our recent decisions upholding it.

Finally, I would note that the WCCA requested guidance on how to apply Smith. According to Supreme Court, their ruling in Smith does not prohibit a compensation judge to review the DSM criteria when evaluating different expert opinions. The Supreme Court explained that pursuant to Smith compensation judges are precluded from making their own diagnoses.

Takeaway: This case upholds Smith, which appears to be the current rule for compensation judges of interpreting and using the DSM criteria in PTSD cases, which will be the standard for the future. Also, this confirms that compensation judges have wide discretion in making credibility determinations, which will be upheld unless there is some significant contrary evidence.