This Note begins with a background of Ohio Supreme Court limitations on the General Assembly's definition of injury in workers' compensation law. Part IV(C) of this Note will analyze other jurisdiction's approaches to the compensability of physical injury caused by mental stimulus and will discuss other aspects and refinements of personal injury in the course of employment. It is proposed that there is a need for reform in Ohio's construction of "any injury"'-one that will embrace the nationwide trends of "uniformly" compensating workers for both physical and mental injury caused by mental stimulus. Ohio currently excludes both types of injuries. Such an exclusion of workers so injured results in an arbitrary and capricious denial of equal protection under the law, which is expressly prohibited by the Ohio Constitution. Part IV(D) of this Note presents an equal protection argument for employees harmed by work-related mental stimuli. A complete understanding of these issues, however, must begin with an understanding of the concept of "injury."
Note, The Need for Workers' Compensation Reform in Ohio's Definition of Injury: Szymanski v. Halle's Department Store, 31 Clev. St. L. Rev. 145 (1982)