Donald Stockman

Donald Stockman, an associate warden at Wasco State Prison, alleged psychiatric injury arising from workplace conflict and an involuntary transfer to Corcoran State Prison, roughly 47 miles away. The WCR found the transfer was a lawful, nondiscriminatory, good faith personnel action that substantially caused his psychiatric injury, thereby barring compensation under Labor Code section 3208.3(h). On reconsideration, the WCAB affirmed, relying on Dr. Donlon's opinion that no disability existed until the May 19, 1997 transfer, and analyzing each element of subdivision (h) in detail. The Board concluded that the transfer was lawful (no violation of civil service transfer rules), nondiscriminatory (all three feuding managers were removed), and taken in good faith under an objective standard, and that it was a substantial cause of the psychiatric injury. Compensation was therefore barred and the Findings and Order affirmed.