Pacific Gas & Elec. Co. v. WCAB, 114 Cal. App. 4th 1174 (2004)

Clifford Bryan filed a workers’ compensation claim against Pacific Gas & Electric Company (PG&E) after he was forced to leave work in October 2001 due to the stress of his job in interacting with customers who did not like the company and due to the financial problems affecting PG&E during that time, including its filing of a Chapter 11 bankruptcy petition in April of 2001; as of that time, Bryan owned approximately $200,000 in PG&E stock. The workers’ compensation judge denied Bryan benefits after concluding that work-related stress was not the predominant cause of his alleged psychiatric injury. The Workers’ Compensation Appeals Board (WCAB) reversed the judge and concluded that Bryan was entitled to benefits. The Court of Appeal reversed the WCAB and held that Bryan was not entitled to benefits due to his alleged anxiety over PG&E’s downsizing, his stock losses or the “future of PG&E and his retirement funds.” However, the Court remanded the action to the WCAB to determine whether the stress of Bryan’s confrontations with “angry, threatening or deceitful customers of PG&E” caused him specific and identifiable work-related stress.