Construing the Ohio Supreme Court’s decision in Armstrong v. John R. Jurgensen Co., 136 Ohio St. 3d 58, 2013-Ohio-2237, an Ohio appellate court held that while there must be a causal relationship between a claimant’s physical injury and his or her mental injury, the two need not necessarily occur contemporaneously. The court acknowledged that passing time would be a factor to be considered in factually determining whether a causal connection had been established, and could also make it more difficult for the claimant to establish such a connection, but the absence of a psychological injury at the time of the physical injury, or soon thereafter, was not determinative. Ohio is among the minority of states that do not provide benefits for purely mental injuries.
See Coleman v. KBO, Inc., 2018-Ohio-763 (Mar. 2, 2018)