Candelaria v. General Electric Company

Robert Lee Candelaria (plaintiff) worked for General Electric Company (GE) (defendant). Before GE, Candelaria was honorably discharged from the military, where he had no problems. Next, Candelaria worked his way up at a company from a plater to foreman to plant manager. The company closed, and Candelaria worked for other employers without issue. At GE, Candeleria began as a janitor, then a forklift operator, and then in a position involving preparing parts for plating. Candelaria worked for different supervisors at GE without issue until he began working for Jewett. Jewett had a reputation as a difficult supervisor, and Candelaria struggled working for Jewett. After another employee quit, Jewett assigned Candelaria that employee’s job duties while still expecting Candelaria to keep up the timing of his previous job duties. Despite Candelaria’s many requests to Jewett and other plant management, no employee was assigned to help Candelaria. One day, as Jewett stood over Candelaria giving him orders, Candelaria began shaking and felt as if he were going to kill Jewett. Candelaria did not attack Jewett but was hospitalized repeatedly for psychological problems. Between hospitalizations, Candelaria returned to work, and Jewett continued to pressure Candelaria, triggering more flare-ups in Candelaria’s condition. Candelaria eventually had a nervous breakdown and was hospitalized again. Candelaria filed a claim for workers’-compensation benefits. Candelaria’s doctor testified that Candelaria did not have any condition that would cause him to misperceive reality. The trial court held that Candelaria’s injury arose out of and occurred in the course of his employment due to actual job stress. GE appealed, arguing that Candelaria did not suffer an accidental injury because it was a gradual psychological injury. GE also argued that Candelaria did not suffer from actual job stress but rather that his condition caused him to distort reality.