Jenson v. Employers Mut. Cas. Co

In Jenson v. Employers Mut. Cas. Co., 161 Wis. 2d 253, 270, 468 N.W.2d 1 (1991), a village clerk-treasurer brought a claim against the village president alleging intentional infliction of emotional distress arising out of alleged statements in which the president publicly accused the clerk-treasurer of dishonesty and incompetence in her capacity as a municipal employee. See Jenson, 161 Wis. 2d at 257-58. In Jenson, the clerk-treasurer argued that intentional acts may not be deemed accidents under the Act. Our supreme court concluded, however, as a matter of law, that "such conduct constitutes an accident as the term is used under the provisions of the Act." Jenson, 161 Wis. 2d at 266. The Court held that "where the work environment is one of the causative factors ... it is immaterial whether the motive is or is not work connected." Jenson, 161 Wis. 2d at 271.