In Ganley v. Upper Darby Twp. (WCAB), ___ A.3d ___, 2025 WL 2967361 (Pa.Cmwlth. Oct. 22, 2025), the Commonwealth Court reversed a workers’ compensation judge’s decision to deny a firefighter’s claim for benefits due to a work-related PTSD injury after he twice experienced events where he had to perform CPR on infants, neither of whom survived. Instead, the court found that those events gave rise to abnormal working conditions sufficient for him to obtain benefits.  

There was no dispute between the township and firefighter that he was suffering from PTSD, but the parties disputed whether those events amounted to abnormal working conditions sufficient for him to obtain workers’ compensation benefits.  

The court first noted that in psychological injury cases under the Workers’ Compensation Act, the issue of whether a claimant has established abnormal working conditions is decided on a case-by-case basis. It also recognized that “some jobs are, by their nature, highly stressful.” In a high-stress working environment, there needs to be a finding that the claimant’s work performance “was unusually stressful for that kind of job or a finding that an unusual event occurred making the job more stressful than it had been.”   

The court ruled that “Claimant was actively involved in attempting to resuscitate two separate unresponsive babies and witnessing each of their deaths. We cannot agree that Claimant’s experience in this regard was a ‘normal’ or ‘expected’ consequence of being a firefighter.” For example, he had never had to do that in his 20-year career, and although firefighters receive training to respond to these types of incidents, there was no evidence that firefighters in the county or across Pennsylvania routinely perform CPR on infants or witness their death.  

The court concluded that the “package of these tragedies, and Claimant’s direct involvement in them, constitutes an abnormal working condition.”