Robert Cocking, a firefighter for the City of Montgomery, filed a complaint alleging he developed post-traumatic stress disorder (PTSD) due to on-the-job incidents. He sought recovery under the occupational disease provision of the Alabama Workers' Compensation Act. The employer argued this claim was non-compensable, stating mental disorders not caused by a physical injury fell outside the act's scope.
The trial court entered a summary judgment for the employer. Cocking appealed. The court pointed out that the act does not expressly exclude purely mental disorders. However, by treating occupational diseases similarly to accidents, which requires injury to the body's physical structure, mental diseases resulting exclusively from nonphysical stimuli are not covered.
Given that Cocking related his PTSD exclusively to emotional trauma and not any physical injury, the trial court's summary judgment for the employer was affirmed.
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