Janitor Stuck Several Times by Improperly Disposed of Hypodermic Needles

In Donovan v. Workmen's Compensation Appeal Board (Academy Medical Realty), 739 A.2d 1156 (Pa. Cmwlth. 1999), a janitor cleaning a dentist's office was stuck several times by improperly disposed of hypodermic needles and suffered a mental injury. The claimant received medical treatment for his physical injury in the way of blood work and booster shots. Finding that the Board erred in categorizing his injury as mental/mental instead of physical/mental, we held that a claimant did not need to prove that he suffered a physical disability that caused a mental disability for which he could receive benefits, but only needed to prove that a physical stimulus resulted in a mental disability. While a physical stimulus need not be disabling, even though it is unwelcome, it still needs to be more than a touching.