The New Jersey Supreme Court reverses lower court decisions in two cases, finding that the defendant public employer erred in its benefits determinations regarding the plaintiffs' claims for accidental disability benefits.
The two plaintiffs are police officers who were public employees of different local police departments and who were members of a police and firefighters' retirement system. The defendant is the board of trustees for the retirement system. The court granted review of both cases together due to commonality of the issues and the defendant.
The first plaintiff responded to a serious motor vehicle accident, where he witnessed a horrific event that led to him suffering from post-traumatic stress disorder and later terminating his employment as a police officer. He subsequently filed a claim for accidental disability benefits, which the defendant denied. The lower court affirmed the defendant's decision, finding that the horrific event was within the first plaintiff's job description and therefore contemplated by his training.
The second plaintiff was a hostage negotiator and had much training on hostage negotiation. The plaintiff responded to a hostage situation and was on the phone with a hostage suspect who begged for the plaintiff's help while he was shot and killed by police. The second plaintiff returned to work but was later diagnosed with post-traumatic stress disorder and major depressive disorder and filed a claim for accidental disability benefits. The defendant denied the second plaintiff's claim. The lower court reversed the defendant's decision and awarded benefits to the plaintiff.
The court granted certification and reviews the two plaintiffs' claims. The court uses a two-step analysis to interpret whether a member of the retirement system has experienced a traumatic event that entitles him or her to accidental disability benefits. First, the court determines whether the member directly experienced a "terrifying or horror-inducing event that involves actual or threatened death or serious injury or a similarly serious threat to the physical integrity of the member or another person." The event must be "of consequence and objectively capable of causing a reasonable person to suffer a disabling mental injury."
If the event meets this first test, the court then uses a five-pronged test to determine whether a member is eligible for accidental...