A recent ruling by an Illinois appellate court has forced the state’s workers’ compensation commission to reconsider a claim made by a Homewood firefighter who suffered from post-traumatic stress disorder (PTSD) after a traumatic incident. The court found that legal precedents support his case and criticized the commission for dismissing his claim too quickly.

The initial decision came from an arbitrator who ruled that Lt. Scott Moran, a 25-year veteran of the Homewood Fire Department, had not sustained an accidental injury “arising out of and in the course of his employment” when he claimed coverage for PTSD symptoms. This decision was upheld by the Illinois Workers’ Compensation Commission. However, Moran appealed the ruling, first to the Cook County Circuit Court and then to the Appellate Court, which ultimately overturned the original decision.

Moran’s PTSD is believed to have stemmed from a house fire on March 30, 2010. As the highest-ranking officer on the scene, he was responsible for coordinating the response involving multiple fire departments. He was preparing to enter the burning building with another firefighter to rescue someone trapped inside when Brian Carey, a fellow firefighter, volunteered to go in instead. While Carey and the other firefighter were inside, the flames intensified, causing severe injuries to Carey, who later died.

Because Carey was the ambulance driver, Moran had to find an alternative transport for him. This added to the emotional weight of the event. Following the fire, the department halted all operations for about 10 days and referred all emergency calls to other agencies. All firefighters at the scene were given access to mental health services and could not return to work until cleared by a psychologist.

In April 2010, Moran sought psychological help and was eventually diagnosed with PTSD. He was cleared to return to duty nine months later, once his doctor determined that he could manage his symptoms effectively.

The arbitrator who initially denied his claim argued that while Moran experienced an emotional reaction to the fire, he had not suffered a physical injury, did not witness Carey’s death, and was not directly involved in the rescue. She also stated that his condition was more related to his personal experiences rather than a direct occupational injury, and awarded his employer a credit of over $7,400 for temporary disability payments.

However, the appellate court challenged this reasoning, pointing out that the lower court had applied a different standard to firefighters, who face unique and extreme stress compared to other workers. The court referenced existing case law stating that whether a worker suffers enough emotional trauma to qualify for compensation should be judged by an objective, reasonable-person standard.

The court emphasized that being outside the burning house does not disqualify an event from being traumatic. It highlighted Moran’s feelings of guilt and responsibility as the incident commander, as well as the department’s own recognition of the event as traumatic—evidenced by the time off and mental health support provided to all firefighters present.

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

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

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