New Mexico’s limits on the duration of workers’ compensation benefits for a mental impairment caused by a workplace physical injury are unconstitutional, the state Supreme Court ruled today April 1.
In a unanimous opinion, the Court concluded that Workers’ Compensation Act caps on benefits for disabilities from mental impairments violated the equal protection clause of the New Mexico Constitution, because workers with those impairments were treated differently than employees with physical impairments resulting from a work-related injury.
The Court wrote in an opinion by Justice Briana H. Zamora, “Both mentally disabled workers and physically disabled workers are impaired in their capacities to perform work. A mental disability compensable under the Act affects workers in the same way as a compensable physical disability does by preventing them from earning a wage because of an on-the-job accident. The idea that mentally disabled workers may be entitled to recover less compensation than physically disabled workers is contrary to the purposes of the Act, which guide our equal protection analysis.”
The Court affirmed a decision of the state Court of Appeals in a case involving a special educator teacher, Ana Lilia Cardenas, who injured a knee while working for Aztec Municipal Schools and suffered a mental impairment because of the injury.
A Workers’ Compensation Administration judge awarded Cardenas 150 weeks of permanent partial disability benefits for the physical injury to her knee. The law limited the duration of benefits for the secondary mental impairment to the maximum allowed for the physical injury.
Cardenas appealed, contending that her mental impairment should have been treated as a separate and distinct injury. She argued there was an equal protection violation in the law because the duration of workers’ compensation benefits for subsequent physical impairments is determined differently than it is for a secondary mental impairment. The Court of Appeals ruled in her favor.
