ALBION, N.Y. — A New York appeals court has upheld the denial of a workers’ compensation claim filed by a corrections sergeant who developed post-traumatic stress disorder after unsuccessfully trying to save the life of an inmate during a medical emergency.
In a June 11 decision, the Appellate Division, Third Department, affirmed a Workers’ Compensation Board ruling that found the sergeant’s PTSD was not a compensable workplace injury under the law that existed at the time of her claim.
Jennifer Croom, a corrections sergeant at Albion Correctional Facility, responded to a medical emergency involving an incarcerated individual she had known years earlier while working at a juvenile residential center, according to court records.
Croom and a facility nurse escorted the woman to the prison hospital unit, where her condition worsened and she became unresponsive. Croom joined others in performing CPR and using an automated external defibrillator before paramedics arrived. The incarcerated individual later died.
After the incident, Croom sought mental health treatment and was diagnosed with PTSD. She filed a workers’ compensation claim and stopped working in November 2023.
A Workers’ Compensation Law Judge initially established the claim, but the Workers’ Compensation Board later reversed that decision and disallowed benefits.
Court says corrections officers were not covered by PTSD exception
At issue was whether Croom qualified for an exception in New York’s workers’ compensation law that applied to certain first responders suffering psychological injuries related to work-related emergencies.
The court found that, at the time of the claim, the law specifically covered police officers, firefighters, EMTs, paramedics, emergency dispatchers and other emergency medical personnel, but did not include corrections officers.
While corrections officers may receive training in first aid, CPR and other lifesaving measures, the court concluded that those responsibilities did not place them within the categories protected by the statute.
“The statute does not expressly or by implication extend to correction officers,” the court wrote.
Judges find incident fell within normal job duties
The court also agreed with the Board’s determination that the stress experienced by Croom was not greater than what similarly situated correction officers could encounter in the normal course of their duties.
According to the decision, testimony showed that responding to medical emergencies and providing lifesaving aid were part of Croom’s responsibilities as a corrections sergeant. Both Croom and a corrections lieutenant testified that such emergencies were not uncommon within the facility, and deaths had occurred there previously.
The court also noted that although Croom had known the incarcerated individual from an earlier job, she testified that her working relationship with the woman was no different from her relationships with other incarcerated individuals.
Based on those facts, the court found substantial evidence supporting the Board’s conclusion that Croom did not sustain a compensable injury under the law then in effect.
New PTSD law did not apply retroactively
The court acknowledged that New York lawmakers enacted a new provision in 2025 that expanded protections for workers filing PTSD, acute stress disorder and major depressive disorder claims related to work-related stress.
However, judges determined the new law could not be applied retroactively to Croom’s case because the Workers’ Compensation Board had already issued its final decision before the statute took effect.
As a result, the court affirmed the denial of benefits.
