Matter of Brown v New York City Tr. Auth.

Holding The Appellate Division affirmed the Workers’ Compensation Board’s denial of benefits, finding that the claimant’s PTSD did not result from stress greater than that ordinarily encountered in his job as a station cleaner. The court determined that witnessing a platform accident and cleaning blood were within the scope of his expected duties, failing to meet the threshold for a compensable accidental injury.

The court’s words

emotional stress-induced psychological injury was considered accidental only if the claimant established that the stress they experienced in the workplace was greater than that which other similarly situated workers experienced in the normal work environment

2026 NY Slip Op 06045, at the official text

Whether an incident amounts to a workplace accident requires the Board to consider whether the alleged stressor is one the claimant should reasonably and ordinarily be expected to encounter in the normal work environment

2026 NY Slip Op 06045, at the official text

the Board's factual determination that claimant did not experience stress greater than any other cleaner on duty in a subway station to establish a compensable injury is supported by substantial evidence

2026 NY Slip Op 06045, at the official text