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Decker v. Oklahoma State University12/21/1988
The dispositive issue presented on certiorari is whether the claimant's heart attack, which was claimed to have been caused by mental stress and anxiety created within the work environment, resulted from a risk reasonably incident to employment. We answer in the affirmative, because there is competent evidence that a change in the administrative structure of claimant's work environment caused the mental stress and that his supervisors knew about, but did nothing to alleviate, the stressful workplace milieu.
FACTS
In August 1981 Kenneth Decker [claimant or worker ] became employed by Oklahoma State Technical University [employer or Oklahoma State Tech] in Okmulgee as a data processing instructor. He taught five junior college level classes each weekday between 8:00 a.m. and 3:00 p.m. His only other duties were to attend faculty meetings and graduation exercises.
From the beginning of his employment until March 1984 the claimant's job performance evaluations were generally above average. In January 1984 a fellow instructor, Ms. C., was appointed data processing program manager. With Ms. C.'s transition to a supervisory job there was no clarification of her responsibilities vis-a-vis the claimant. Shortly after her appointment, Ms. C. asked the claimant to work overtime and evenings without compensation to develop a new curriculum. When the claimant refused to perform the additional work his relationship with Ms. C. became strained, causing him to suffer from insomnia and anxiety.
In March 1984 the claimant received from his supervisor, Mr. B., a below-standard job evaluation. Mr. B. testified that the claimant was "very upset" about this report. Because the claimant "could see the handwriting on the wall," he became worried about the possible loss of his job. On April 12, 1984 Oklahoma State Tech Director, Dr. K., told the claimant that he was a poor instructor and if he did not dramatically improve he would be forced to resign. The claimant testified that this meeting aggravated his anxiety and insomnia. Dr. K. sent the claimant a letter on April 16, 1984 confirming the April 12 conversation. The claimant performed his teaching duties until April 30, 1984 when he suffered a myocardial infarction while in his office.
Claimant sought workers' compensation benefits. The trial judge found that the claimant's heart attack was not compensable under the Act because it was not an accidental personal injury arising out of and in the course of employment. The order denying compensation was affirmed by a three-judge review panel. The Court of Appeals vacated the order, holding there was competent evidence, and none to the contrary, that the claimant did suffer an accidental injury arising out of and in the course of employment. It also noted that one of the claimant's medical witnesses gave uncontroverted testimony that the worker 's heart attack was "quite likely . . . related to the stress from his employment." The employer and insurance carrier now seek review by certiorari. Although we reach the same conclusion as did the Court of Appeals, we grant certiorari to afford precedential guidance with an indepth discussion of the applicable legal principles.
THE APPLICABLE LAW
A presumption arose under ยง 27 of Oklahoma's Workers' Compensation Act that a claim for injury or death of a worker comes within the Act's provisions. Any reasonable doubt is resolved in the claimant's favor. Despite this presumption, the claimant bears the burden of producing competent evidence to establish the fact of injury and its compensability under Oklahoma law.
Compensation is due an injured employee only when the harm suffered
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