For many of us, work can be physically draining, intellectually taxing and just plain drudgery. For others, work can become a traumatizing environment where workers can be hurt in numerous ways that do not result in physical injuries. Over 100 years ago, with the passage of the Workers' Compensation Act, workers conceded the power to sue employers in tort for injuries that occurred on the job in favor of a systematic approach that would compensate them only for medical care and a wage payment without a cost-of-living adjustment. At that time, immediate worries included the horrors of coal mines and factories, and other physical dangers of the Industrial Revolution workplace.

The act even stated its initially physical focus in the long-standing definition of an “injury” in 77 P.S. Section 411—”only violence to the physical structure of the body, and such disease and infection as naturally results therefrom.” In 1972, however, the General Assembly amended this section to pertain to “an injury to an employee, regardless of his previous physical condition … arising in the course of his employment and related thereto, and such disease or infection as naturally results from the injury or is aggravated, reactivated or accelerated by the injury.”

The Commonwealth Court recognized the meaning of the change in University of Pittsburgh v. Perlman, 405 A.2d 1048 (Pa. Cmwlth. 1979), a case brought by the widow of Dr. Lawrence Perlman, a doctor employed as director of a clinic, the coordinator of an ambulatory health program and a professor of internal medicine. The extensive pressures and responsibilities of Perlman's positions, and the university's apparent lack of support and cooperation, created serious anxiety and fear for his job and reputation. He sought psychiatric help, and when the university became aware of the situation, he was placed on an indefinite leave of absence with pay. He committed suicide five days later.