Sparks v. Tulane Medical Center Hospital & Clinic
Louisiana Supreme Court
546 So. 2d 138 (1989)
Sedonia Sparks (plaintiff) was employed as a supervisor at Tulane Medical Center Hospital & Clinic (the hospital) (defendant). On April 6, 1987, Sparks received physical threats after she suspended two employees for failing to perform their required duties. Sparks became upset and left work, and she immediately began experiencing headaches that a doctor diagnosed as tension headaches caused by work-related stress. Sparks also experienced anxiety, loss of appetite, insomnia, and nightmares. A psychiatrist diagnosed Sparks as having a job-related psychological adjustment disorder, and a clinical social worker found that Sparks’s condition was disabling and work-related. Sparks was unable to work for five months, and she sought workers’-compensation benefits from the hospital. The trial court denied Sparks’s claim after concluding that Sparks had not suffered an injury by accident, as required for recovery under Louisiana’s workers’-compensation statute. However, the appellate court reversed and awarded Sparks benefits. The hospital appealed to the Louisiana Supreme Court.
Rule of Law
Holding and Reasoning (Calogero, J.)
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