A New York court has ruled against Jennifer Croom, a correction sergeant, who sought workers' compensation benefits after developing post-traumatic stress disorder (PTSD) following a traumatic incident at work. The Appellate Division of the Supreme Court of the State of New York issued its decision on June 11, 2026, affirming the Workers' Compensation Board's earlier ruling that denied her claim. This ruling affects not only Croom but also sets a precedent for other correction officers seeking similar benefits in the future.
The case, officially titled Matter of Croom v. New York State Dept. of Corr. & Community Supervision (CV-24-1886), centers around an incident in 2023 when Croom was working at the Albion Correctional Facility. During her shift, an incarcerated individual, whom she had known from a previous job, suffered a medical emergency. Despite efforts from Croom, a facility nurse, and paramedics to revive the individual, the inmate died. Following the incident, Croom sought mental health treatment and was diagnosed with PTSD, leading her to file a claim for workers' compensation benefits.
The Workers' Compensation Board initially established her claim for work-related PTSD. However, after further review, the Board disallowed the claim in October 2024, leading to Croom's appeal to the Appellate Division. The court's ruling focused on the legal definitions of compensable injuries under New York's Workers' Compensation Law.
The Appellate Division, led by Judge Aarons, ultimately affirmed the Workers' Compensation Board's decision. The court stated, "substantial evidence supports the Board's decision that claimant did not sustain a compensable injury." The ruling emphasized that emotional stress-induced psychological injuries are only considered accidental if the claimant can prove that the stress experienced was greater than that which other similarly situated workers typically face in the normal work environment.
Croom argued that she qualified for an exception under Workers' Compensation Law § 10 (3) (b), which protects certain first responders from having their claims disallowed based on the level of stress experienced. However, the court found that correction officers are not included in the statutory definition of those eligible for this exception. The ruling stated that correction officers do not fall under the category of "persons certified to provide medical care in emergencies," as defined by the law.
The court's decision also addressed a new statutory provision (Workers' Compensation Law § 10 [3] [c]) that would take effect in June 2025, which prohibits disallowing claims based on the argument that the stress was not greater than what typically occurs in the workplace. However, the court ruled that this provision could not apply retroactively to Croom's case, as her claim had already been adjudicated before the law took effect.
The implications of this ruling are significant for correction officers and other employees in similar roles. It reinforces the existing legal standard that requires workers to demonstrate that their emotional stress is beyond what is typically experienced in their work environment to qualify for compensation. This could make it more challenging for correction officers and others in high-stress jobs to receive benefits for psychological injuries.
Moving forward, this ruling may deter future claims from correction officers who experience PTSD or similar conditions due to their work. It highlights the need for clear definitions and protections for workers in high-stress environments, as the current laws may not adequately cover all scenarios faced by these employees.
As for next steps, Croom's legal team may consider appealing the decision to a higher court. However, details regarding an appeal or any related cases were not available in the court filing. The outcome of this case may prompt discussions about potential changes in legislation to better protect correction officers and similar workers in the future.