To Be Compensable, Must Worker's Psychological Condition Be 'Caused By' a Physical Injury?

Or Merely Arise From Incident In Which That Worker Also Suffered Physical Injury

Shaun Armstrong v. John R. Jurgenson Co. et al., Case no. 2012-0244

Second District Court of Appeals (Clark County)

ISSUE: When the legislature amended a section of the state's workers' compensation law in 2006, did the new language inserted in the statute impose a requirement that a worker may recover benefits for a psychological condition that arises from a workplace accident in which the worker also suffered a physical injury only if the claimant can show that his psychological condition was caused by his physical injury?