Daniel v. Department of Corrections

Tony Daniel (plaintiff) worked for the Department of Corrections (the department) (defendant) as a probation officer. In early 1995, four female defense attorneys who had interacted with Daniel during probation-violation hearings alleged that Daniel had sexually harassed them. Daniel’s supervisor investigated the complaints, and Daniel was eventually suspended for 10 days without pay. When Daniel returned to work, he claimed that he felt harassed by his supervisor and by the complaining defense attorneys. A psychologist diagnosed Daniel as suffering from depression caused by work stress and the disciplinary investigation and proceedings. In June of 1996, Daniel sought workers’-compensation benefits from the department, based on a mental disability that he claimed had arisen from the disciplinary proceedings against him. A magistrate found that Daniel was experiencing the disabling conditions of depression, anxiety, and uncontrolled anger, which had started during the disciplinary proceedings. The magistrate thus held that Daniel was entitled to benefits because Daniel’s mental disability arose out of his employment. The department appealed to the Worker’s Compensation Appellate Commission (WCAC), arguing that under § 418.305 of Michigan’s workers’-compensation statute, an employee who is injured by reason of the employee’s own intentional and willful misconduct cannot recover benefits. The WCAC found that Daniel had repeatedly engaged in sexually harassing behavior despite being aware of rules that prohibited such conduct. The WCAC thus held that Daniel’s injury arose from his own intentional and willful misconduct and denied Daniel’s claim for benefits. The Michigan Court of Appeals reversed the WCAC’s decision after finding that Daniel’s acts did not constitute intentional and willful misconduct within the meaning of the Michigan statute. The department appealed to the Michigan Supreme Court.