New Mexico Supreme Court Strikes Down Workers’ Compensation Act Provision as Unconstitutional

In a landmark decision, the New Mexico Supreme Court has declared portions of the Workers’ Compensation Act unconstitutional for discriminating between physical and mental injuries. The ruling came in the case of Ana Lilia Cardenas, a special education teacher who suffered both a physical knee injury and a subsequent mental injury while employed at Aztec Municipal School District. While Cardenas received compensation for her physical injury, her claim for the mental injury was denied additional benefits solely due to its nature as a mental health condition. This treatment starkly contrasted with how another physical injury, stemming from the initial one, would have been compensated.

The court’s decision highlighted the outdated distinction between physical and mental injuries, underscoring the essential equality between the two types of impairments. Chief Justice Shannon Bacon criticized the act for its arbitrary allocation of benefits, pointing out the absence of evaluation for subsequent mental injuries and calling the differentiation "antiquated".

Despite arguments from the school district and its insurer that the caps on mental injury compensation were to keep claims predictable and prevent overburdening the workers’ compensation fund, the justices found these justifications to be "generic, unsupported assertions". They asserted that treating mental and physical impairments differently was not only unjust but also misaligned with the Workers’ Compensation Act’s purpose to compensate workers for lost earning capacity, thereby maintaining the social welfare system and shifting the burden of protecting workers onto the industry.

The ruling signifies a crucial step towards addressing the long-standing bias against mental health in workers’ compensation claims, aligning with contemporary understandings of mental health’s importance and impact. It calls for a reevaluation of similar provisions across states, pushing for legislation that recognizes the parity between physical and mental health in the workplace.