Employment & Labor Law for Public Safety Agencies

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Stress Related Claims and Defenses

     Illinois appellate court overturns the termination of a fire paramedic that physically and verbally abused a patient who was in physical and emotional distress. The disciplinary board failed to assess whether the paramedic’s bipolar disorder and depression affected his actions. “... we conclude that it was unreasonable for the Board to have discharged plaintiff for cause without having made a specific finding as to whether plaintiff’s illnesses were substantially related to his misconduct.” The matter was remanded for evidentiary findings. Hermesdorf v. Wu, #2-05-0877, 25 IER Cases (BNA) 1703, 2007 Ill. App. Lexis 288 (2d App. Dist.).
     Appeals court affirms order to reinstate a deputy sheriff, who received a worker’s comp. stress award. County could not refuse to reinstate the deputy because she needs a stress-free work environment. Hanna v. Los Ang. Co. Sheriff’s Dept., #B150425, 67 Cal. Comp. Case 1320, 2002 Cal. Wrk. Comp. Lexis 1528, 102 Cal. App.4th 887, 125 Cal.Rptr.2d 686 (2nd App. Dist. 2002). {N/R}
     Appeals court reinstates ADA reinstatement attempt of ex-sergeant who shot up her father’s grave, inflicted wounds on herself, and overdosed on drugs. Sheriff failed to consider her reemployment for any jobs in the department. McKenzie v. Dovala, #99-8084, 237 F.3d 538, 2001 U.S. App. Lexis 3844, 11 AD Cases (BNA) 936 (10th Cir.). [2001 FP 60]
     Montana Supreme Court upholds the right of a public safety employee to sue his employer for failing to counsel & debrief him for the mental trauma he suffered after witnessing a teenager’s gunshot wounds. Stratemeyer v. Lincoln Co., 915 P.2d 175, 53 Mont. 245 (1996). [1996 FP 126]
     CA appellate court orders reinstatement of an officer who has recovered from a mental condition, despite a provision which prevents him from wearing a firearm and irrespective of the fact the employing agency did not have positions for unarmed officers. Raygoza v. Co. of Los Angeles, 17 Cal. App. 4th 1240, 21 Cal.Rptr.2d 896 (1993). [1994 FP 125-6]
     Sheriff did not have to reassign a jail deputy to the courthouse to alleviate her stress, even if her stress was intensified because he allegedly mistreated her. Dewitt v. Carsten, 941 F.Supp. 1232, 1996 U.S.Dist. Lexis 14188 (N.D.Ga.). [1997 FP 122-3]
     300 lb. firefighter applicant loses discrimination suit. Although Michigan law protects overweight persons, the city lawfully rejected the plaintiff for his inability to deal with stress. Howard v. City of Southfield, #95-1014, 1996 U.S. App. Lexis 25290. [Michigan is the only state to prohibit weight discrimination; Mich. Comp. Laws Sec. 37.2202(1)(a)]. {N/R}
     Depressed police officer could not sue under A.D.A. because of her reassignment to light duty during her recovery from depression. Thompson v. City of Arlington, 838 F.Supp. 1137 (N.D.Tex. 1993). [1994 FP 77-8]
     Years of severely stressful service entitled a police officer to an ordinary, but not a line-of-duty, disability pension. Ryndak v. River Grove Police Pension Bd., 618 N.E.2d 606 (Ill. App. 1993). [1994 FP 60-1]
     Town police chief had implied authority to arrange for stress counseling for a subordinate, thus obligating the municipality for the payment of the psychologist’s bill. Elam v. Town of Luther, 787 P.2d 1294 (Okla. App. 1990).
     Firefighter who suffered psychic injuries was not entitled to a disability pension where department could assign him to other duties. Cadden v. Workmen’s Comp. Bd., 579 A.2d 1378 (Pa. Cmwlth. 1990).
     Teacher entitled to sick pay for taking day off to play golf on doctor’s orders because of job-related stress. In Matter of Williams, San Diego Comm. on Professional Competence, reported in Chicago Sun-Times, page 21, July 24, 1988.

     Although a pension board found that a police officer was not longer disabled, the NYPD was justified in rejecting his return to duty for psychological reasons. Ciacciullo v. Kelly; City of N.Y. v. NYC Civ. Serv. Cmsn., #50, 2006 N.Y. Lexis 958 (N.Y. 2006). [2006 FP Jul]
     MSPB judge overturns the firing of a public employee because she had body odor, and reduces the penalty to a 90-day suspension. Her punishment was lightened because she suffers from depression. Heilpern v. Dept. of the Army, #PH-0752-03-0271-I-1, 42 (2067) G.E.R.R. (BNA) 687 (MSPB-AJ 2003; rptd. 2004). [2004 FP Oct]
     Hawaii’s Supreme Court upholds a disability claim by a firefighter who suffered emotional distress because of what he perceived to be a flawed promotional process, and a threat of retaliation by the chief when he appealed the outcome. Davenport v. C&C of Honolulu, #23141, 100 Haw. 481, 60 P.3d 882, 2002 Haw. Lexis 850 (Haw. 2002; released 2003). [2003 FP May]
     California appeals court denied a stress claim resulting from a reduction in force demotion. Injuries caused by “a lawful, nondiscriminatory, good faith personnel action” are not compensable under the state’s workers’ comp. laws. City of Oakland v. Workers’ Compensation Appeals Board, #A095800, 02 C.D.O.S. 5208, 120 Cal.Rptr.2d 873, 2002 Cal. App. Lexis 4227 (Cal. App. 1st Dist. 2002). [N/R]
     Supreme Court declines to review an appellate holding that rejected federal death benefits for the widow of a police officer who killed himself due to job-related stress. Yanco v. U.S., #00-5058, 258 F.3d 1356 (Fed. Cir. 2001); rev. den., #01-674, 122 S. Ct. 921, 2002 U.S. Lexis 530 (2002). [2002 FP Apr]
     Federal appeals court rejects the stress defense by a terminated firefighter, who claimed an inability to successfully work with various fellow firefighters. Aldrup v. Caldera, #01-50369, 2001 U.S. App. Lexis 26347 (5th Cir. 2001). [2002 FP Feb]
     Ohio arbitrator holds that a captain’s job stress and work-related depression were compensable under the city’s “Injury Leave” provisions and should not have been charged to his accumulated Sick Leave. Newark, Ohio (City of) and Licking Co. FOP L-127, FMCS #00/07760, 115 LA (BNA) 1608 (Slonaker, 2000). [2001 FP 157-8]
     Kentucky allows PTSD benefits for a police officer who shot a mentally deranged man who assaulted them with a knife. Lexington-Fayette Govt. v. West, #1999-CA-002462, 2000 Ky. App. Lexis 109. [2001 FP 107-8]
     Pennsylvania disallows PTSD claims by an officer who endured a long standoff with a mentally disturbed man with a loaded firearm. A “confrontation with an armed suspect may be anticipated in the course of an officer’s duties.” Philadelphia (City of) v. Civil Serv. Cmsn. (Ryder), #55-EAP-1999, 772 A.2d 962, 2001 Pa. Lexis 1083. [2001 FP 107-8]
     Pennsylvania denies stress claim to officer who attended to two officers who were shot, and suffered from PTSD. Rydzewski v. W.C.A.B., (Philadelphia), #856 C.D. 2000, 767 A.2d 13, 2001 Pa. Commw. Lexis 16, 2000 WL 1946655. [2001 FP 29]
     Appeals court affirms award to whistleblower who suffered anxiety disorder after reporting corrupt practices. Abdallah v. N.Y. City, #86031, 279 A.D.2d 723, 719 N.Y.Supp.2d 198, 2001 N.Y. App.Div. Lexis 248 (3rd Dept. 2001). [2001 FP 45]
     Employee who suffered psychological injuries after witnessing an attack on a coworker is not eligible for workers’ compensation benefits. The injuries must be caused by the operation of the employer’s business. Kmart v. WCAB (Fitzsimmons), #9 E.D. 1999, 561 Pa. 111, 748 A.2d 660, 2000 Pa. Lexis 708. {N/R}
     Officer who suffered PTSD from a shooting loses her suit challenging management’s decision to temporarily assign her to administrative duties and order a psychological exam. Davis-Durnil v. Vil. of Carpentersville, #98-C-7618, 128 F.Supp.2d 575, 2001 U.S. Dist. Lexis 918 (N.D. Ill.). [2001 FP 60-1]
     Part-time corrections officer not entitled to worker’s comp. benefits for stress caused by decreased availability of work time. Dept. of Corr. v. WCAB (Garcia), 76 Cal. App.4th 810, 1999 Cal. App. Lexis 1054, 90 Cal.Rptr.2d 716. {N/R}
     N.C. appellate court panel awards benefits to a police officer who suffered depression after repeated exposure to offenders and crime victims. Pulley v. City of Durham, 468 S.E.2d 506 (N.C. App. 1996). [1997 FP 124]
     Illinois appellate court orders a police retirement board to give a duty-incurred stress pension to a 47-year old officer who felt old, inadequate and afraid. Job pressures need not be the sole cause of his stress to recover, if these aggravated his condition. Robbins v. Bd. of Trustees, Carbondale, 670 N.E.2d 1177 (Ill. App. 1996). [1997 FP 27-8]
     Court overturns management and orders a stress pension for a corrections officer who could not cope with a confined work area. Fasanaro v. County of Rockland, 632 N.Y.S.2d 453 (Sup. 1995). [1996 FP 78]
     Homicide detective who could not cope with job stress is denied a duty-related disability pension for psychic injury. Clowes v. WCAB, 639 A.2d 944 (Pa. Cmwlth. 1994). [1995 FP 61]
     Ohio supreme court rejects occupational disease benefits for a mentally disabled firefighter. His condition was solely caused by job-related stress, not accompanied by physical trauma. The court found the claimant’s “anxiety disorder” was non-compensable. Ramaldo v. City of E. Cleveland, 65 Ohio St.3d 281, 603 N.E.2d 975 (1992). [1994 FP 44]
     A divided Vermont Supreme Court concludes that work-induced stress did not disable a police officer, because there was no proof it accelerated his progressive brain tumor. Burlington (City of) v. Davis, 624 A.2d 872 (1993). [1994 FP 44-5]
     Appellate court rejects emergency dispatcher’s claim for occupational traumatic stress reaction. Claimant failed to prove condition was uniquely caused at work. Marcus v. Arlington Co., 425 S.E.2d 525 (Va. App. 1993). [1993 FP 125]
     Appellate court denies stress pension to fire inspector who complained that job pressures caused disorientation and panic. City of Springfield v. Industrial Cmsn., 573 N.E.2d 836 (Ill. App. 1991). [1992 FP 109-110]
     Police officer was entitled to stress-related disability pension for alcoholism, even though he did not drink at work, did not suffer physical problems associated with alcohol abuse, but did exhibit alcohol-related disciplinary problems over a four year period. Hudnut v. Hargis, 561 N.E.2d 820 (Ind. App. 1990).
     Jail officer not entitled to “stress pension” absent proof his psychotic condition was caused or aggravated by prior altercations with inmates. Heavey v. Regan, 557 N.Y.S.2d 481 (A.D. 1990).
     Emergency dispatcher not entitled to work-related retirement benefits for stress-induced psychological condition resultant from understaffing. Jensen v. N.M. State Police, 788 P.2d 382 (N.M. App. 1990).
     N.Y. Appellate court rejects ulcer disability claim; even if caused by job stress, disease was not the result of an accident. Evans v. City of New York, 535 N.Y.S.2d 716 (A.D. 1988).
     Deputy sheriff working as only officer on island, on call 24 hours a day, did not show that mental injury was caused by work-related stress. Walsh v. Knox County, 535 A.2d 438 (Me. 1988).
     Airport parking checker resigns job because of “situational” depression; allowed to collect unemployment benefits. Chicago Daily Law Bull., page 1, July 30, 1987.
     Nurse receives $5,000 settlement for developing stress-related ulcer because of her fear that patients have AIDS. 25 (1205) Gov. Empl. Rel. Rep. (BNA) 381 (March 16, 1987).
     Police officer was properly discharged following suicide attempt resulting from stress of marriage, career, and finances, despite conflicting evidence. City of Greenwood v. Dowler, 492 N.E.2d 1081 (Ind. App. 1986).
     State Supreme Court affirms $28,250 award for ulcer condition aggravated by stressful job assignments. Egeland v. City of Minneapolis, 344 N.W.2d 597 (Minn. 1984).

     In a case where a NOPD officer was fired for not giving an I-A statement due to acute stress, the Civil Service Cmsn. ordered reinstatement. If management believed that the officer was a malingerer, it should have followed its own procedures and instructed the officer to present himself for a medical examination by a doctor of the city's choosing. Reinstatement was conditioned on a qualifying medical exam.
     On appeal, a three-judge panel affirmed, writing that "in light of the evidence that [the officer] suffered from a debilitating psychological condition that prevented him from performing his duties as a police officer, it does not appear that the CSC abused its discretion or acted in an arbitrary or capricious manner in conditioning the officer's return to duty on a medical clearance." Allen v. Dept. of Police, # 2009-CA-1375, 2010 La. App. Lexis 1112 (4th Cir.).
     Appellate court rejects the appeal of a state trooper who fled from two marked state police vehicles during a high speed pursuit, left threatening messages on an answering machine of the mother of one of his children, and caused a lengthy standoff with police and rescue personnel after he barricaded himself in his residence. The five-judge panel declined to hold these were excusable lapses in judgment, induced by stress. Bassett v. Fenton, #506506, 2009 NY Slip Op 9338, 68 A.D.3d 1385, 891 N.Y.S.2d 195, 2009 N.Y. App. Div. Lexis 9147 (3d Dept.).
     Two years prior to his retirement, a deputy sheriff with 25 years of service was accused by the media of colluding with a murder suspect. He was fired, and later rehired, but was assigned to lesser duties. He sought work-related disability retirement benefits. Because the State's psychiatrist testified that his symptoms were exacerbated after he was initially fired due to a false accusation, it was a line-of-duty incidents. Debilitating anxiety or stress over loss of duties can be considered a work-related injury, even if there were significant outside stressors. Jernigan v. Florida Mgmt. Serv., #1D07-5011, 2008 Fla. App. Lexis 16213 (1st Dist.).
      MSPB judge overturns the firing of a public employee because she had body odor, and reduces the penalty to a 90-day suspension. Her punishment was lightened because she suffers from depression. Heilpern v. Dept. of the Army, #PH-0752-03-0271-I-1, 42 (2067) G.E.R.R. (BNA) 687 (MSPB-AJ 2003). [2004 FP Oct]
      Divided Michigan appellate court allows an employee who was disciplined for harassing women, to recover comp. benefits for the depression which followed his suspension. Daniel v. WCAC Dept. of Correction, #224423, 248 Mich. App. 95, 638 N.W.2d 175,2001 Mich. App. Lexis 215 (2001). [2002 FP Jul]
     Strikes and Retaliation Second Circuit enforces an arbitration award even though the union breached the no-strike clause in the bargaining agreement. Mulvaney v. SMWIA L-38, 288 F.3d 491, 2002 U.S. App. Lexis 7720, 169 LRRM (BNA) 3089 (2nd Cir. 2002). [N/R]
    California appeals panel affirms termination of an “overstressed” public employee who threatened to kill her supervisor. Agency was not required to reassign her or place her on extended medical leave. Davis v. Civ. Serv. Cmsn., 55 Cal. App.4th 677, 64 Cal.Rptr.2d 121, 1997 Cal. App. Lexis 445. [1997 FP 140]
     Louisiana supreme court upholds police commission’s decision to reduce punishment from termination to a suspension and unpaid medical leave. The filing of false reports and the failure to perform his duties was mitigated by the trooper’s work-related depression. Dept. of State Police v. Mensman, 671 So.2d 319 (La. 1996). [1997 FP 45]
     Federal court upholds termination of subordinate who struck his supervisor. Employee’s long-term mental condition did not excuse his misconduct. Marino v. United States, 3 AD Cases (BNA) 447 (D.Mass 1993); affirmed, 3 AD Cases 704, 25 F.3d 1037. [1994 FP 157-8]
     Federal court upholds the termination of a public employee with an “explosive personality disorder.” Employer was not required to accommodate his psychological disabilities. Mazzarella v. U.S. Postal Serv., 849 F.Supp. 89, 3 AD Cases (BNA) 239 (D.Mass. 1994). [1994 FP 125]
     Episode of depression did not excuse officer’s conduct. Appellate court upholds termination of police officer who threatened to kill his commanding officer. Moorehead v. N.Y.C.T.A., 593 N.Y.S.2d 263 (A.D. 1993). [1993 FP 157]
     Severe stress from working several jobs did not excuse a deputy sheriff’s misappropriation of a handgun. Greiner v. Greene County, 576 N.Y.S.2d 665 (A.D. 1991). [1992 FP 173-4]
     Officer could not be fired for threatening to kill mayor and chief; he was mentally ill and incapable of conduct unbecoming. He should be separated for medical unfitness. Perry v. Philadelphia Civil Serv. Cmsn., 529 A.2d 616 (Pa. Cmwlth. 1987).
     Firefighter’s Vietnam stress disorder was no defense to off-duty shooting incident. Hansen v. City of Gloversville, 484 N.Y.S.2d 694 (A.D. 1985).
     Personality disorders and psychological conflict no excuse for poor judgment and failure to control one’s emotions. McCoy v. Kamradt, 483 N.E.2d 544 (Ill. App. 1985). [1986-6 FP 5-6]
     Job stress excused retail theft; resignation set aside on grounds employee would have been dismissed. Dept. of Public Safety, Div. of State Police, 461 A.2d 98 (N.H. 1983).
     Illinois supreme court reverses termination of off-duty officer who threatened sergeant with his weapon; not “willful” misconduct. Kloss v. Bd. of Fire & Police Cmsnrs., Mundelein, 449 N.E.2d 845 (Ill. 1983).
     Cop who threatened and shot fellow officer may be entitled to a medical pension. Walsh v. Board of Fire & Police Cmsnrs., Orland Park, 449 N.E.2d 115 (Ill. 1983).

     Connecticut appellate court affirms the denial of benefits for psychic injuries suffered by a police officer who was in a gun battle at the end of a high-speed chase. Although the plaintiff's disorder was an occupational disease, it was not compensable under the Act because it did not arise from a physical injury. Biasetti v. City of Stamford, #AC 30867, 1 A.3d 1231, 123 Conn. App. 372, 2010 Conn. App. Lexis 366.    
      D.C. Circuit dismisses ex-CIA agent’s claim for emotional injury arising from an earlier shooting; the Federal Employees’ Compensation Act provided an exclusive remedy. Spinelli v. Goss, #05-5270, 446 F.3d 159, 2006 U.S. App. Lexis 11171 (D.C. Cir. 2006). [2006 FP Aug]
     Postal worker who had witnessed the 1986 massacre in Edmond, Okla. was “disabled” with PTSS -- but was not a qualified individual because she was unable to work in an office. Mason v. Avaya, 2004 U.S. App. Lexis 422, 15 A.D. Cases (BNA) 153 (10th Cir. 2004). {N/R}
     Arbitrator upholds the termination of a public employee who, under the influence of alcohol, left a profane voice mail message for his supervisor. His “stress defense” failed because he lacked any medical substantiation. City of Anaheim and Municip. Empl. Assn., 119 LA (BNA) 270 (Gentile, 2003). [2004 FP Apr]
     A flight attendant scheduled to work on United Airlines flight 93 that was hijacked on Sep. 11, 2001 is ineligible for workers comp. benefits. Her post-traumatic stress disorder was not triggered while at work. “If we were to accept petitioner’s argument, off-duty police officers, firefighters, and others whose jobs are inherently risky could seek compensation benefits when a fellow employee was injured or killed while taking the employee’s place ...[and] ... no authority exists to support that position.” Stroka v. United Airlines, #A-4274-01, 835 A.2d 1247, 2003 N.J. Super. Lexis 364 (N.J. App. Div. 2003). [2004 FP Feb]
     Arizona state trooper has wins disability benefits for PTSD. The state claimed that shooting suspects was not an unexpected event as required by state compensation laws. Expert testimony supported his claim, and the compensation judge ruled “that shooting and killing another human being in the line of duty is an extraordinary stress related to the employment.” [David] Mogel v. Dept. of Public Safety, Ariz. Indus. Cmsn. (2002). {N/R}
     Pennsylvania Supreme Court finds that a death threat to a police officer and his family was unusual, even for a law enforcement officer, because it included a $50,000 bounty and death threats to the officer’s children at school. These were not part of a normal officer’s experiences and stress compensation benefits were appropriate. City of Pittsburgh v. Logan, #95 WAP 2001, 810 A.2d 1185 (2002). {N/R}
     New York Workers’ Comp. Board finds that a corrections officer was entitled to benefits for depression after he was to exposed potential blood borne pathogens after he cut his hand. In re Elmira Corr. and Rec. Center, #9970-7141, 2001 NYWCLR (LRP) Lexis 335 (NYWCB 2001). {N/R}
     Officer awarded benefits for psychic injuries, following a six minute standoff with an armed man. Philadelphia v. Civil Serv. Cmsn.(Ryder,)712 A.2d 350, 1998 Pa. Commw. Lexis 354; appeal pending, 1999 Pa. Lexis 3578. {N/R}
     Pennsylvania courts reject PTSD claims of two police officers. In the one case, a sergeant was indicted for manslaughter following a shooting; in the other, a gun was pointed at an officer’s head by a violent person. Philadelphia v. WCAB (Brasten), 728 A.2d 938, 1999 Pa. Lexis 1298; Young v. WCAB (New Sewickley Police), 737 A.2d 317, 1999 Pa. Commw. Lexis 635. [1999 FP 172-3]
     Montana Supreme Court denies PTSD pension to firefighter that suffered psychiatric difficulties after an explosion in which he was burned. Most of his psychological problems preceded the accident. Yarborough v. Montana Insur. Auth., 938 P.2d 679 (Mont. 1998). [1998 FP 108]
     Wisconsin appeals court holds that an officer who is involved in a typical shooting cannot, as a matter of law, claim disability benefits from job stress. Panel did not close the door to claims arising out of unusual shootings, however. Bretl v. Labor Cmsn., 553 N.W.2d 550 (Wis. App. 1996). [1997 FP 123]
     North Carolina appellate court grants temporary total disability benefits to a vocational instructor who was assigned to a correctional facility, and witnessed an inmate fight. Jordan v. Central P.C.C., 476 S.E.2d 410 (N.C. App. 1996). [1997 FP 123-4]
     Pennsylvania appellate court reinstates disability benefits to a corrections worker who suffers from PTSD related to a prison riot. Wertz v. WCAB (DoC), 683 A.2d 1287 (Pa. Cmwlth. 1996). [1997 FP 124]
     Appellate court approves a “line-of-duty” stress-related pension for an officer who suffered psychological problems after he accidentally shot himself. Dillon v. Seattle Police Pension Bd., 916 P.2d 956 (Wash. App. 1996). [1997 FP 62]
     14 British police officers who were psychologically traumatized from the Hillsborough football stadium disaster receive ú1,200,000 for PTSD. Ref: “Stress Fracture”, 28 June 1996 Police Review (London UK) 22. [1996 FP 156-7]
     Psychic injury claim by corrections officer, who had been held as a hostage, was properly denied. The time between the incident and the disability was too long to be causally related. Ferber v. N.Y. Dept. of Corrections, 632 N.Y.S.2d 684 (A.D. 1995). [1996 FP 78-9]
     Police officer denied disability benefits for PTSD following his participation in a barricaded gunman episode. Parson v. WCAB, 642 A.2d 579 (Pa. Cmwlth. 1994). [1995 FP 77]
     Federal appeals court upholds $126,000 verdict for emotional distress, awarded an employee who suffered PTSD after being stuck with a discarded, blood-filled hypodermic needle. His fear of AIDS transmission was reasonable. Marchica v. Long Island RR., 9 IER Cases (BNA) 1560 (2nd Cir. 1994). [1995 FP 29-30]
     Deputy sheriff who suffered severe anxiety from assisting a teenage gunshot-suicide victim was not entitled to recover workers” comp. benefits. Mental and stress claims must be accompanied by a physical injury in Montana. Stratemeyer v. Lincoln Co., 855 P.2d 506 (Mont. 1993). {N/R}
     Corrections official need not be inside the prison during a riot to suffer post trauma stress disorder. Wertz v. Dept. of Corrections, 609 A.2d 899 (Pa. Cmwlth. 1992). [1993 FP 28-9]
     NY Court of Claims upholds policy of Corrections Dept. to contest all stress-related claims by officers except those taken hostage. Huzar v. St. of New York, 590 N.Y.S.2d 1000 (Ct. Cl. 1992). [1993 FP 93-4]
     Appellate court disallows disability benefits for firefighter who suffered acute stress following emergency calls where deaths ensued. Heisler v. Regan, 594 N.Y.S.2d 462 (A.D. 1993). [1993 FP 141]
     Pennsylvania appellate court affirms duty-related death benefit award to widow of detective who killed himself. He became depressed while investigating serial killings. City of Scranton v. WCAB, 583 A.2d 852 (Pa. Cmwlth. 1989). [1992 FP 13]
     Psychic trauma resulting from accidental discharge of an officer’s firearm, which wounded her lieutenant, was not a compensable “injury” under Ohio’s workers” compensation law. Hayes v. City of Toledo, 62 Ohio App.3d 651, 577 N.E.2d 379 (1989). [1992 FP 14]
     Appellate court denies duty-related retirement pension, allegedly aggravated by post-shooting stress syndrome. Claimant had a pre-existing personality disorder. Croskey v. Dist. Col. Pol. & F/F Ret. Bd., 596 A.2d 988 (D.C. App. 1991). [1992 FP 158]
     Prison psychologist who suffered post traumatic stress disorder, following his role in hostage release incident, is denied compensation. His mental suffering was not accompanied by necessary physical injury. Fenwick v. Okla. St. Penitentiary, 792 P.2d 60 (Okla. 1990).
     Arizona supreme court allows claim that police officer suffered post-traumatic stress syndrome from a violent confrontation that occurred 24 years earlier, and later manifested itself in excessive alcoholism. Henry v. Indus. Cmsn. of Ariz., 754 P.2d 1342 (Ariz. 1988).

     Federal appeals panel revives a disability discrimination suit filed by an FBI agent-trainee who suffered from PTSD. Sleep is a major life activity. Superiors ended his career after finding an unsigned resignation letter. Desmond v. Mukasey, No. 07-5139, 2008 U.S. App. Lexis 13803 (D.C. Cir.).
     A Virginia public employee’s migraine headaches, acid reflux pain, stomach cramps, diarrhea, skin rash and insomnia were a result of job stress, and not a physical injury. She could not sue for the negligent infliction of emotional distress without evidence of other physical injury caused by the alleged coworker harassment. King v. City of Chesapeake, #2:05cv617, 2007 U.S. Dist. Lexis 21709 (D.Va.).
     Appellate court affirms the rejection of a correction officer’s job-related stress claim. He chose to work at a maximum-security prison and should have anticipated that he would interact with dangerous inmates and unusual situations, including inmates throwing urine and fecal matter. Babich v. W.C.A.B. (PA Dept. of Corrections), #1472C.D.2006, 2007 Pa. Commw. Lexis 169.
     Federal Merit Board finds undisputed evidence established that an employee was angry, severely depressed, anxious, suffered from post traumatic stress disorder, suicidal ideation, psychosis, was obsessed with management, and posed a threat to his colleagues. His psychiatric condition was precipitated and exacerbated by job-related stress to the point it became disabling such that disability was adequately proved. Thorne v. Office of Personnel Management, #AT-844E-06-0227-I-1, 2007 MSPB 75 (MSPB 2007).
     Because stress can aggravate diabetes, the Dept. of Correction was liable for the treatment costs due to the officer’s job-related post-traumatic stress disorder. Lewis v. N.C. Dept. of Corr., #COA03-1447, 606 S.E.2d 199, 2004 N.C. App. Lexis 2385 (2004). {N/R}
     Pension board’s determination that an officer was not entitled to a line of duty pension because post traumatic stress syndrome, from which he suffers, did not result from one isolated event, but from series of stressful occasions, is not against manifest weight of the evidence. Coyne v. Milan Police Pension Board, #3-03-0066, 2004 Ill. App. Lexis 396 (3rd Dist. 2004). {N/R}
     NYC judge overturns decision to deny disability benefits to a former NYPD internal affairs officer that uncovered corruption and then (a) suffered harassment by a few anonymous coworkers, (b) was given undesirable assignments and (c) was subjected to the silent treatment by other officers. Matter of Jeffrey W. Baird v. Kelly, #101889/20032004 NY Slip Op 50394U, 3 Misc.3d 1104A, 787 N.Y.S.2d 676,2004 N.Y. Misc. Lexis 554. Reversed: See 2006 NY Slip Op 5, 25 A.D.3d 311, 806 N.Y.S.2d 578. The officer was entitled to ordinary disability retirement benefits, but not to “accidental” disability retirement benefits.
     Arbitrator reinstates, but without back pay, a private sector employee who left work without management’s consent. He suffered from job stress and could have misunderstood that he had permission to leave work. SMG and Intn’l Alliance L-12, FMCS Case 03/00685-6, 118 LA (BNA) 1239 (Goldberg 2003). {N/R}
    Although a police sergeant had a alcohol problem and the mother of his children was a heroin addict, an appellate court sustained a worker’s comp. claim for job-related stress, due to feelings of “isolation” among his coworkers. City of Lindsay v. WCAB, #F037841, 67 Cal. Comp. Cas 1 2002 Cal. Wrk. Comp. Lexis 1205 (5th App. Dist. 2002). {N/R}
     Appeals court affirms comp. benefits for a police lieutenant who was fired and was later exonerated and reinstated. The chief caused him to be ostracized and stripped of his authority. The “environment was abnormal for any person, not just a police officer.” Bor. of Beaver v. WCAB (Rose), #18 C.D. 2002, 810 A.2d 713 (Pa.  Cmwlth. 2002). {N/R}
     The New Jersey Supreme Court revives the workers’ comp. claims filed by two police employees who suffered work-related, delayed onset, post traumatic stress disorder. PTSD can be either a disease or an accident. Brunell v. Wildwood Crest Police Dept., #A-126/127 Sept. Term 2001, 176 N.J. 225, 822 A.2d 576, 2003 N.J. Lexis 559 (N.J. 2003). [2003 FP Sep]
     Pennsylvania appeals court affirms right of a woman police lieutenant to recover benefits for stress resulting from male harassment because of her promotions. Sloan v. City of Pittsburgh Police Dept., #1024 C.D. 2002 (Pa. Commw. 2003); prior decis. at 779 A.2d 598, 2001 Pa. Commw. Lexis 432 (2001). [2003 FP Jun]
     Article: “Correctional employee stress and strain,” and “Examining the health risks for corrections professionals,” 63 (6) Corrections Today 83 and 110 (Oct. 2001), American Correctional Assn., {N/R}
     Appellate court overturns disability pension for a firefighter who experienced depression from repeated disciplinary action. Haywood v. Amer. River Fire Dist. 67 Cal. App.4th 1292, 79 Cal.Rptr.2d 749, 1998 Cal. App. Lexis 962. [1999 FP 29]
     A Superior Court jury in Los Angeles has awarded a LAPD civilian employee $1,957,120 for PTSD, following her unlawful arrest. Jones v. City of Los Angeles, 98-06 Cal.Bar.J. Trials Digest (Cal. Super.Ct. 1998). {N/R}
     Stress and anxiety from job-related sex discrimination did not excuse a woman firefighter from completing paramedic training in 3 years; ADA claim fails. Leisen v. Shelbyville, 968 F.Supp. 409 (S.D. Ind. 1997). Affirmed; 1998 U.S. App. Lexis 21256. [1998 FP 108]
     Appellate court rejects suit for emotional distress; supervisor pretended to shoot the plaintiff with a toy gun, causing her to collapse and to believe that she had been shot. Workers’ comp. claim allowed, however. Henson v. Crisp, 946 P.2d 1252, 1997 Wash. App. Lexis 1986. [1998 FP 44]
     State employee who was videotaped while looking in a coworker’s desk and was later questioned by the state police is entitled to worker’s comp. benefits for stress. Prettyman v. State of N.J., 298 N.J. Super 580, 689 A.2d 1365 (A.D. 1997). [1997 FP 163-4]
     Officer entitled to an ordinary stress pension because of a disciplinary demotion imposed on him; supplemental “line-of-duty” benefits should be denied. Woldrich v. Vancouver Police Pension Bd., 928 P.2d 423 (Wash. App. 1996). [1997 FP 61]
     Florida appellate court denies workers” comp. benefits to a woman officer who was sexually abused by her superior. Her emotional trauma, though severe, was not accompanied by a physical injury. Liberty Correctional Instit. v. Yon, 671 So.2d 194 (Fla. App. 1996). [1997 FP 44-5]
     Pennsylvania supreme court denies psychic injury benefits to police chief who received harassing phone calls from the mayor. Romanies v. WCAB, 644 A.2d 1164 (Pa. 1994). [1995 FP 125]
     Illinois appellate court disallows a stress pension for an ex-officer who was forced to resign after fondling a citizen. Jagielnik v. Bd. Tr. of Mundelein, 1995 Ill. App. Lexis 265. [1995 FP 12-13 & 109-100]
     Depression induced by a grand jury investigation of a police dept. is an insufficient basis to award job-related disability benefits to a police employee who was not the focus of the probe. North Huntingdon Twp. v. WCAB, 644 A.2d 227 (Pa.Cmwlth. 1994). [1995 FP 110]
     Widow accepts $7,500 to settle suit against the Postal Service following her husband’s on-the-job suicide. Complaint alleged harassment, retaliation and disability discrimination. Barnes v. U.S. Postal Service, #93-162, 32 (1576) G.E.R.R. (BNA) 982 (E.D.Cal. 1994). {N/R}
     Connecticut Supreme Court upholds an award of workers’ compensation benefits to a public employee who suffered severe stress when he was falsely accused of sexual assault while on duty. Crochiere v. Bd. of Educ., 227 Conn. 333, 630 A.2d 1027 (1993). [1994 FP 108]
     Police officer who faced an internal investigation for brutality was not entitled to a line-of-duty pension because of anxiety and elevated blood pressure. Arbogast v. Baltimore Co., 95 Md. App. 674, 622 A.2d 808 (1993). [1994 FP 43]
     Mississippi supreme court upholds an award of total temporary disability benefits to an employee suffering from psychotic depression after a superior deliberately put “pressure and stress” on the claimant. Borden Inc. v. Eskridge, 604 So.2d 1071 (Miss. 1992). [1994 FP 43-4]
     Corrections officer who was lawfully fired for assaulting an inmate, was entitled to workers” comp. benefits for job-related depression. Beames v. Warren Co. Sheriff’s Dept., 593 N.Y.S.2d 127 (A.D. 1993). [1994 FP 13-14]
     Police officer denied compensation benefits for psychosis induced by an overreaction to a disciplinary reprimand. Squilla v. WCAB, 606 A.2d 539 (Pa.Cmwlth. 1991). [1993 FP 29]
     Texas appellate court denies compensation benefits to employees who are distressed by employer reprimands. Duncan v., Employer’s Casualty Co., 823 S.W.2d 722 (Tex. App. 1992). [1992 FP 125]
     Oregon appellate court denies benefits to police chief who suffered hypertension from stress caused by diminished job security. Sibley v. City of Phoenix, 107 Or. App. 606, 813 P.2d 69 (1991). [1992 FP 125]
     City employee awarded disability pay for post-traumatic stress disorder (PTSD) resultant from his arrest for an offense he was acquitted of. Williams v. Reg. Transit Auth., 546 So.2d 150 (La. 1989).
     Police chief not entitled to a line-of-duty pension for mental instability because he was suspended for his refusal to be interviewed by federal investigators following his arrest. Rentfrow v. Police Pension Fund of Effingham, 525 N. E. 2d 176 (Ill. App. 1988).
     Firefighter’s workers comp. award for stress-induced illness reversed on appeal. His failure to be permanently confirmed as a captain was the apparent cause of his mental distress. Sorenson v. City of Omaha, 230 Neb. 286, 430 N.W.2d 696 (1988).
     Psychological injury without preceding physical injury compensable; stressful job environment including demotions and ethnic slurs from coworkers may have led to depression. Battista v. Chrysler Corp., 517 A.2d 295 (Del. Super. 1986).
     Portland’s woman police chief gets $49,524 annual disability for stress claim induced by criticism of her tenure. In re Penny Harrington, City of Portland, Oregon (10/21/86); Note: this ruling has been appealed and modified.
     Job stress caused by fellow employees compensable: harassment produced psychic injuries to transit employee. Martin v. Rhode Island Public Transit Auth., 506 A.2d 1365 (R.I. 1986).
     Unsuccessful attempt to fire employee can produce job stress, entitling him to a duty-related disability pension. Traub v. Board of Retirement of Los Angeles County E.R.A., 195 Cal. Rptr. 681 (Cal. 1983).
     A nervous breakdown can entitle claimant to a duty-related disability pension, when induced by denial of his pending claim for ordinary disability on other grounds. Goode v. NYC Transit Police Dept., 454 N.Y.S.2d 212 (Misc. 1982).
     Incompetence on the job may be aggravated or induced by stress entitling employee to duty-related pensions. Tingler v. City of Tampa, 400 So.2d 146 (Fla. App. 1981).

     Arbitrator rejects a stress defense and holds that a police officer, who exhausted his extended sick leave after being accused of rape, abandoned his job when he failed to return to work and was not entitled to reinstatement. Stress defense failed because he voluntarily canceled therapy visits. City of Newark and FOP Ohio, FMCS #050809-05133-8 (Byrne, 2006). [2006 FP Oct]
     California appeals court rejects the job-related claim of a stress-disabled university police officer. Cal. Govt. Code 3208.3c (1993), established a higher threshold of compensability for job-related psychiatric injuries, and was not an unconstitutional impairment of contract under Art. I Sec. 10 of the U.S. Constitution. Pearl v. WCAB, #B125991, 97 Cal.Rptr.2d 411, 81 Cal. App.4th 1033, 2000 Cal. App. Lexis 504 (6th Dist. 2000); Rev. Gtd. #S090553, 2000 Cal. Lexis 7496 (10/3/2000). {N/R}
     The time limit for filing for disability or medical benefits for PTSD start when the condition is diagnosed, and not when the symptoms first occur. Flint v. Town of Bernalillo, 878 P.2d 1014 (N.M. App. 1994). {N/R}
     A disability claim for job-induced mental illness must be timely; time begins running from the precipitating event, and not when the psychological injury is discovered. Arthrell v. WCAB (Pa.St.Police), 624 A.2d 686 (Pa.Cmwlth. 1993). [1994 FP 44]
     Stress-induced “situational reaction” to employment difficulties did not excuse adherence to the time limits set to appeal his termination. Handicap laws were of no avail. Kein v. United States, 749 F.Supp. 286 (D.DC 1990). [1992 FP 173]
     Arizona supreme court allows claim that police officer suffered post-traumatic stress syndrome from a violent confrontation that occurred 24 years earlier, and later manifested itself in excessive alcoholism. Henry v. Industrial Cmsn. of Ariz., 754 P.2d 1342 (Ariz. 1988).
     Finding that employee’s development of diabetes was related to stress of job accident adequately supported despite fact that only minority of physicians agreed. Castaldo v. Fee Oil Co., 520 N.Y.S.2d 289 (A.D. 1987).
     Police officer can receive duty disability benefits for mental injury only if greater than day-to-day strain all employees experience. Vil. of Random Lake v. Labor & Ind. Review Cmsn., 415 N.W.2d 577 (Wis. App. 1987).
     Suicide attempt is not compensable in South Dakota when produced solely by mental stimuli or stress, even if work-related. Lather v. Huron College, 413 N.W.2d 369 (S.D. 1987).
     Officer who suffered off-duty heart attack not entitled to benefits when heavy smoking and other personal factors. Wills v. Public Sfty. Pers. Retire. Bd., 743 P.2d 944 (Ariz. App. 1987).
     California appeals court says obesity is a job-related illness if overeating is induced by job stress. Conflicting evidence resolved in employer’s favor. Power v. WCAB, 224 Cal.Rptr. 758, 179 Cal. App.3d 775 (1986).
     Chief could terminate stress victim for mental depression, but pension board would have to approve his medical pension. Benson v. Ft. Dodge Police Pension Bd., 374 N.W.2d 392 (Iowa 1985).
     Child molester officer sought disability pension for his “mental instability’; court rejects claim for “moral turpitude.” Henry H. v. Board of Pension Cmsnrs. for Los Angeles, 197 Cal.Rptr. 636, 149 Cal. App.3d 965 (1983).
     Hypertension is an “illness” not an “injury.” O’Connor v. Board of Trustees of La. St. Police, 429 So.2d 450 (La. App. 1983).
     Officer who suffered recurrence of Vietnam induced nightmares not entitled to disability in line of duty; claimed his promotion to sergeant aggravated his psychological problems. Kirkwood v. Dist. of Col. Police and Firemen’s Retirem. Bd., 468 A.2d 965 (D.C. App. 1983).
     Police officer who threatened girlfriend and suitor with weapon not entitled to duty disability benefits for “nervous breakdown.” McDaniel v. City of Albuquerque, 653 P.2d 885 (N.M. App. 1982).
     Appellate court affirms “stress” pension even where preexisting character deficiencies were present. Gurule v. Board of Pension Cmsnrs. for Los Angeles, 178 Cal.Rptr. 778, 126 Cal. App.3rd 523 (1981).
     Good news for fat smokers with heart disease; “stress” may also be a factor, and may entitle applicants to duty-related pension. Liberty v. Police and Firemen’s Retirem. and Relief Bd., 410 A.2d 191 (D.C. App. 1979).
     Mental strain can be duty-related, Hairford v. State Police Retirem. Bd., 360 So.2d 220 (La. App. 1978).
     Mental illness – significance of a surgeon’s report: McShane v. City Civil Serv. Cmsn., City of New York, 378 N.Y.S.2d 706 (A.D. 1976).
     Recently acquired mental illness: Penebre v. Dzaluk, 378 N.Y.S. 767 (A.D. 1976).

     Book: Traumatic Stress in Police Officers: A Career-length Assessment from Recruitment to Retirement (2009) by D. Paton, J. Violanti, K. Burke & A. Gehrke, Charles C Thomas Pub., ISBN-13: 9780398078935.
     Trauma Resilience Training for Police: Psychophysiological and Performance Effects, Bengt B. Arnetz et al., 24 Journal of Police and Criminal Psychology (Springer) 1-9 (2009).
     Article: Officer Needs Assistance: Police Officers’ Attitudes and Mental Health After Critical Incident Involvement, by Andrew M. Peters, 9 (1) Law Enforcement Executive Forum 53-66 (2009).
     Article: A Prospective Study of Trait Anger and PTSD Symptoms in Police, by Susan M. Meffert et al., 21 (4) Journal of Traumatic Stress 410–416 (Aug. 2008).
     University of Buffalo pilot studies have shown, that "officers over age 40 had a higher 10-year risk of a coronary event compared to average national standards; 72 percent of female officers and 43 percent of male officers, had higher-than-recommended cholesterol levels; and police officers as a group had higher-than-average pulse rates and diastolic blood pressure." NIOSH/Buffalo Cardio-Metabolic Occupational Police Stress Study news (9-25-2008).
     Article: Susan M. Meffert et al. (Aug. 2008) A Prospective Study of Trait Anger and PTSD Symptoms in Police, 21 (4) Journal of Traumatic Stress 410-416.
    Report: Mental Health Advisory Team (MHAT-V) Operation Iraqi Freedom 06-08: Iraq; Operation Enduring Freedom 8:  Afghanistan. Washington, D. C: Office of the U. S. Army Surgeon General, February 14, 2008.
     Article: Tara A. Hartley et al. (2007) Associations between Major Life Events, Traumatic Incidents, and Depression among Buffalo Police Officers, Intern. J. of Emer. Mental Health 9 (1): 25-35.
     Article: Campsie, R.L., Geller, S.K. & Campsie, M.E. (2006).
Combat stress, in Kennedy, C.H. & Zillmer, E.A. (Eds.), Military psychology: Clinical and operational applications (pp. 215-240). New York: Guilford.
     Book: Miller, L. (2006). Practical police psychology: Stress management and crisis intervention for law enforcement. Springfield, IL: Charles C Thomas.
     Presentation: Best, S.R. Common Issues in Returning Veterans: What Is a “Normal” Response to Combat? At the International Association of Chiefs of Police, Police Psychological Services Section, Boston, 2006.
     Presentation: Ritchie, E.C. and S. Curran. Warrior Transition by Army Reserve and National Guard Personnel from Combat Operations in Iraq to Policing in the United States.  At the International Association of Chiefs of Police, Police Psychological Services Section, Boston, 2006.
     Article: Bray, R. M., L.L. Hourani, et al.  2005 Department of Defense Survey of  Health Related Behaviors Among Active Duty Military Personnel.  Research  Triangle Institute International, December 2006.
     Article: Tolin, D. F. and E.B. Foa, “Sex Differences in Trauma and Posttraumatic Stress Disorder:  A Quantitative Review of 25 years of Research,” American Psychological Association Psychological Bulletin 132 (6) (2006), 959-992.
     Report: Mental Health Advisory Team (MHAT-II).  Operation Iraqi Freedom-II.  Washington, D.C.:  Office of the U. S. Army Surgeon General, January 30, 2005.
     Article: Neylan, T.C., A. Brunet, N. Pole, S.R. Best, T.J. Metzler, R. Yehuda, and C.R. Marmar, “PTSD Symptoms Predict Waking Salivary Cortisol Levels in Police Officers,” Psychoneuroendocrinology 30 (2005); 373-381.
     Article: Otte, C., T.C. Neylan, N. Pole, T. Metzler, S.R. Best, C. Henn-Haase, R. Yehuda, and C.R. Marmar,” Association Between Childhood Trauma and Catecholamine Response to Psychological Stress in Police Academy Recruits,” Biological Psychiatry 57 (2005): 27-32.
     Article: Pole, N., T.C. Neylan, S.R. Best, S. Orr, and C.R. Marmar, “Effects of Fear-Potentiation on Physiologic Response to Acoustic Startle in Urban Police Officers with Posttraumatic Stress Symptoms,” Journal of Traumatic Stress (9) (2005), 471-479.
     Book: Sherman, N. (2005). Stoic warriors: The ancient philosophy behind the military mind. New York: Oxford University Press.
     Article: John M. Violanti and Anne Gehrke (2004) Police Trauma Encounters: Precursors of Compassion Fatigue, Intern. J. of Emer. Mental Health 6 (2): 75-80.
     Article: Foa, E.B., T.M. Keane, and M.J. Friedman, eds. Effective Treatment for PTSD. New York: Guilford Press, 2004.
     Article: Friedman, M.J. “Acknowledging the Psychiatric Cost of War,” The New England Journal of Medicine 351 (2004), 75-77.
     Article: Curran, S. (2003). Separating fact from fiction about police stress. Behavioral Health Management, 23, 1-2.
     Article: Hoge, C.W., C.A. Castro, S.C. Messer, D. McGurk, D.I. Cotting, and R.L. Koffman. “Combat Duty in Iraq and Afghanistan, Mental Health Problems, and Barriers to Care,” The New England Journal of Medicine 351 (1) (2004), 13-22.
     Article: Richard L. Levenson Jr. and Lauren A. Dwyer (2003) Peer Support in Law Enforcement: Past, Present, and Future, Intern. J. of Emer. Mental Health 5 (3): 147-152.
     Article: Paton, D, Violanti, J.M. & Smith, L.M. (Eds.) (2003). Promoting capabilities to manage posttraumatic stress: Perspectives on resilience. Springfield, IL: Charles C Thomas.
     Article: Ruzek, J. and Watson, P., “Early Intervention to Prevent PTSD and Other Trauma-Related Problems,” PTSD Research Quarterly 12 (2001), 4.  White River Junction, Vermont:  The National Center for Post-Traumatic Stress Disorder, 2001.
     Article: Paris, J. (2000). Predispositions, personality traits, and posttraumatic stress disorder. Harvard Review of Psychiatry, 8, 175-183.
     Article: Violanti, J.M. (2000). Scripting trauma: The impact of pathogenic intervention, in J. Violanti, D. Paton & C. Dunning (Eds.), Posttraumatic stress intervention: Challenges, issues, and perspectives (pp. 153-165). Springfield: Charles C Thomas.
     Article: “British Policing and the Ottawa Shift System Easing the Stress of Rotating Shifts,” Jan. 2000 FBI Law Enf. Bull. (
     Article: “The FBI’s critical incident stress management program and “Managing undercover stress: the supervisor’s role” Feb. 1999 FBI Law Enf. Bull. (
     Book: Leonard Territo and James Sewell (1999) Stress management in law enforcement, Carolina Academic Press, Durham, N.C. The text is organized into eight sections, starting with the psychological, physiological, and social consequences of stress. The sections that follow focus on coping behaviors, suicide and its impact on the family, trauma and vicarious traumatization. The last two parts discuss the psychological services in law enforcement that can assist an officer.
     Article: Bowman, M.L. (1999). Individual differences in posttraumatic distress: Problems with the DSM-IV model. Canadian Journal of Psychiatry, 44, 21-33.
     Article: Dunning, C. (1999). Postintervention strategies to reduce police trauma: A paradigm shift, in J.M. Violanti & D. Paton (Eds.), Police trauma: Psychological aftermath of civilian combat (pp. 269-289). Springfield: Charles C Thomas.
     Article: Paton, D. & Smith, L. (1999). Assessment, conceptual and methodological issues in researching traumatic stress in police officers, in J.M. Violanti & D. Paton (Eds.), Police trauma: Psychological aftermath of civilian combat (pp. 13-24). Springfield: Charles C Thomas.
     Article: D. Clark (2007) Crisis Response Tools for Law Enforcement, 74 (12) The Police Chief (IACP) 94.
     Book: Schlenger, W.E., J.A. Fairbank et al. “Epidemiology of Combat-Related Posttraumatic Stress Disorder,” in Posttraumatic Stress Disorder:  A Comprehensive Text, ed. P.A. Saigh and J.D. Bremner. Boston: Allyn and Bacon, 1999.
     Book: Bowman, M.L. (1997). Individual differences in posttraumatic response: Problems with the stress-adversity connection. Mahwah, NJ: Erlbaum.
     Article: Adler, A. B., M. A. Vaitkus, and J.A. Martin, “Combat Exposure and Posttraumatic Stress Symptomatology among U.S. Soldiers Deployed to the Gulf War.”  Military Psychology, 8 (1), 1-14, 1996.
     Article: Southwick, S.M., C.A. Morgan, A. Darnell, J.D. Bremner, A.L. Nicolaou, L.M. Nagy, and D.S. Charney, “Trauma-Related Symptoms in Veterans of Operation Desert Storm: A 2-year Follow-Up,” American Journal of Psychiatry 152 (1995), 1150-1155.
    Article: “Ranking police stressors,” 75 (2) Psychological Reports 824-826. Top stressors were from killing someone in the line of duty and experiencing the line-of-duty death of a fellow officer (1994).
     Article: “Stressful events, work-family conflict, coping, psychological burnout, and well-being among police officers,” 75 (2) Psychological Reports 787-800 (1994). Anonymous responses from 828 officers who responded to a survey in Toronto. {N/R}
     Article: “Patterns of PTSD among police officers following shooting incidents: a two-dimensional model and treatment implications,” 2 (3) Journal of Traumatic Stress 247-257 (1989).
     Article: “Psychiatric morbidity in policemen and the effect of brief psychotherapeutic intervention,” 10 (3) Stress Medicine 151-157 (1994).
     Article: “Shooting incidents: does the memory ever fade?” by Andrew Smotzer, 9 (2) The ASLET Journal 52 (Mar/Apr 1994). Discusses the effects of “post shooting trauma” and “critical incident syndrome” which is the subject of a FLETC course (Lesson plan 6190.02. Note: ASLET is now defunct.
     Book: Critical Incidents in Policing, Dr. James Reese, Editor. DoJ-FBI. (1990).

     See also: Mental Illness and Disability; Suicide Related.

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