The Illinois Workers’ Compensation Commission may need to revisit a claim filed by a Homewood firefighter who suffered from post-traumatic stress disorder (PTSD), following a recent ruling by the state appellate court. The court determined that legal precedents support the firefighter’s case, and the commission was too quick to dismiss his claim.

Lt. Scott Moran, a 25-year veteran of the Homewood Fire Department, initially faced rejection of his workers’ compensation claim by an arbitrator, who concluded that he had not experienced an accidental injury directly tied to his job. This decision was later upheld by the Illinois Workers’ Compensation Commission. However, after appealing through the Cook County Circuit Court and then the Appellate Court, the ruling was overturned.

The incident that led to Moran’s PTSD occurred on March 30, 2010, during a house fire in which multiple departments were involved. As the highest-ranking officer on the scene, Moran was responsible for coordinating the firefighting efforts. He was preparing to enter the burning building with another firefighter to rescue someone believed to be trapped when Brian Carey, the ambulance driver, volunteered to go in instead. While Carey and the other firefighter were inside, the flames suddenly intensified, causing severe injuries to Carey, who later died from his wounds.

Because Carey was the ambulance driver, Moran had to find an alternative transport for him, which delayed the response. After the incident, the fire department halted all operations for about 10 days and referred all calls to other agencies. All firefighters at the scene were given access to mental health services, and none were allowed to return to work until cleared by a psychologist. Moran sought psychological help in April 2010 and was diagnosed with PTSD a few weeks later.

Moran was eventually cleared to return to duty nine months after the fire, as his doctor confirmed he could manage his symptoms. However, the arbitrator overseeing his workers’ compensation claim ruled that he had not sustained a physical injury and did not witness the death of his colleague or participate in the rescue. She also noted that his emotional reaction was more related to personal circumstances than a direct occupational injury, leading to a $7,400 credit for temporary disability paid to him by the employer.

The appellate court, however, found that the lower court had applied a stricter standard to Moran’s case because he is a firefighter. The court emphasized that firefighters face unique and inherent stresses not typically encountered in other professions. It referenced previous rulings stating that whether a worker has experienced sufficient emotional trauma should be judged by an objective, reasonable-person standard.

The court acknowledged that even though Moran was outside the building during the incident, the event was still traumatic. They cited his feelings of guilt and responsibility as the incident commander, and pointed out that the fire department itself deemed the situation serious enough to grant all firefighters time off and mental health resources.

“Clearly, this is not the kind of event that an employee would normally experience in the course of their job,” the court wrote. “Moran’s psychological injuries resulted from a single, traumatic event, and he is entitled to compensation for his psychological disability.”

The decision was delivered by Justice Bruce D. Stewart, with Justices William Holdridge, Thomas Hoffman, Donald Hudson, and Sheldon Harris concurring.

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