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Watson v. Melman, Inc.

106 So.2d 433 (1958)

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Watson v. Melman, Inc.

Florida District Court of Appeal
106 So.2d 433 (1958)

Facts

Vennie M. Watson (plaintiff) was working at a sewing machine for Melman, Inc. (defendant) when she was hit by a small wooden spool a coworker had tossed toward a nearby trash can. Watson was not injured by the spool other than a slight discoloration in her skin behind her ear where the spool had struck her. Watson suffered neurosis because of her injury despite the lack of significant physical effects. Watson’s teenage son had been killed by a blow to his head. Watson was also under significant stress as a divorced mother who had to work hard to financially support her surviving child. Because of her neurosis, Watson was unable to continue working, and she filed a claim for workers’-compensation benefits for temporary total disability. A deputy commissioner of the Florida Industrial Commission found that although Watson suffered no organic disability, Watson did suffer traumatic neurosis because of her accident, and her claim should be allowed. The full commission reversed, finding that Watson did not suffer an injury and denying benefits. The full commission emphasized that the deputy commissioner had found no organic disability and pointed to Florida workers’-compensation law, which provided that a mental or nervous injury is not compensable if caused by fright or excitement only. Watson appealed.

Rule of Law

Issue

Holding and Reasoning (Pearson, J.)

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