A New York appeals court on Thursday affirmed a Workers’ Compensation Board decision denying benefits to a correction sergeant who claimed work-related post-traumatic stress disorder after an incarcerated person died following a medical emergency.
According to 2026 NY Slip Op 03709, filed in the Appellate Division, Third Department, a corrections sergeant was working at Albion Correctional Facility in 2023 when an incarcerated person she had known from prior employment experienced a medical emergency. The officer and a facility nurse took the person to the hospital unit, where the person became unresponsive. The officer and others performed CPR and used an automated defibrillator, but the inmate died.
The officer later sought mental health treatment, was diagnosed with PTSD and filed a workers compensation claim. A workers compensation law judge established the claim for work-related PTSD, but the board reversed in October 2024 and disallowed it.
On appeal, the officer argued the board should consider a newly enacted statutory provision that bars disallowance of certain PTSD, acute stress disorder and major depressive disorder claims based on a finding that the stress was not greater than that normally experienced at work. The court rejected the argument, finding the provision took effect June 4, 2025, after the board’s October 2024 decision, and did not apply retroactively.
The court also rejected the argument that she qualified under a statutory exception covering certain first responders and emergency personnel. The court said correction officers are not named in the statute, and CPR or first-aid training does not make a correction officer a person certified to provide medical care in emergencies.
The court said substantial evidence supported the board’s finding that the officer did not experience stress greater than that experienced by similarly situated workers in a normal work environment. The court affirmed the board’s decision.