Work Related Anxiety Disorder With Panic Attacks In Ohio
Commission Relied Upon Report of Doctor As Certain Degree of Flexibility Should Be Maintained When Dealing With Psychiatric Conditions:
In State ex rel. Kroger v. Indus. Comm. (1997), 80 Ohio St.3d 483, 1997 Ohio 324, 687 N.E.2d 446, the employer had challenged the psychological report of Dr. Blythe arguing that she had relied, in part, on nonallowed conditions.
The claimant's claim had been allowed for anxiety disorder with panic attacks.
In her November 6, 1991 C-84, Dr. Blythe listed the claimant's conditions as post-traumatic stress disorder, panic attacks, and dysthymia.
The court noted that, ideally, the diagnoses contained on a disability form should mirror exactly the conditions allowed in the claim; however, the court determined that some degree of flexibility seems particularly important when dealing with psychiatric conditions.
The court noted that Dr. Blythe had consistently referred to the same symptoms as being the cause of the claimant's disability and that many of the symptoms from which the claimant was suffering are common to all three diagnoses.
As such, the court concluded that the commission had not abused its discretion in relying upon the report of Dr. Blythe.