Chicago Board of Education v. Industrial Commission

Vincent Moore (plaintiff) was an elementary school teacher employed by the Chicago Board of Education (BOE) (defendant). Over the course of several years of employment, Moore experienced multiple stressful incidents, including assaults, injuries, and robberies, some of which were perpetrated by students. Moore was also required to complete substantial amounts of daily paperwork, which typically took several hours to complete after the teaching day was over. Starting at the end of the summer break before Moore’s twelfth year of teaching, Moore took a leave of absence from his teaching position to seek treatment and counseling for mental illness. The BOE denied Moore’s request for reinstatement following his leave because Moore failed the BOE’s psychiatric evaluation. Moore filed a compensation claim with the Industrial Commission (IC) (plaintiff), which handled workers’ compensation and other occupational claims, under Illinois’s Occupational Diseases Act (ODA), arguing that the gradually compounding stressors of his employment had caused a compensable occupational disease. At an arbitration hearing, Moore’s psychiatric social worker, Deborah Gessner, testified that Moore’s mental illness was caused by his employment. Moore admitted during testimony that his relationship with his family was strained and that he had a history of psychiatric issues. The IC awarded Moore benefits under ODA. On appeal, the trial court affirmed. The BOE appealed to the Illinois Appellate Court, arguing that Moore had failed to prove that his mental illness was a compensable occupational disease.