Housing Authority of Portland v. Zimmerly

Employer seeks review of an order of the Workers’ Compensation Board that affirmed the referee’s decision that claimant’s mental disorder is compensable. Employer is correct that the Board erroneously applied the “material contributing cause” test, rather than requiring claimant to prove that her work conditions were the major contributing cause of her mental disorder. Aetna Casualty Co. v. Aschbacher, 107 Or App 494, 812 P2d 844 (1991).

Because the issue may recur on remand, we also address employer’s argument that the Board erred in concluding that the conditions causing claimant stress are…