The Commonwealth Court of Pennsylvania ruled in favor of a firefighter seeking workers’ compensation for post-traumatic stress disorder, finding that his experience of twice performing unsuccessful CPR on infants constituted an “abnormal working condition.” The Commonwealth Court reversed the Workers’ Compensation Appeal Board, which had upheld a judge’s denial of benefits for Brian Ganley.
Brian Ganley, a firefighter for Upper Darby Township in Pennsylvania for nearly 20 years, experienced two traumatic incidents within a 30-month period. In November 2018, he responded to a call and performed CPR on a two-week-old infant who could not be revived. In May 2021, a father brought a nine-month-old, non-breathing infant into the fire station, and Ganley again performed unsuccessful CPR. After the second incident, Ganley’s mental health symptoms intensified, leading to a diagnosis of PTSD and his departure from work. The parties agreed his PTSD was work-related but disputed whether the causative events were abnormal working conditions within the meaning of the Workers’ Compensation statute.
Conflicting expert testimony was presented at hearing. Fire Chief Derrick Sawyer testified that performing CPR is a normal duty and that “death is not rare.” The Workers’ Compensation Judge found Sawyer “totally credible” and concluded that the events Ganley experienced, while traumatic, were “simply not extraordinary or abnormal for first responders,” and denied his claim for benefits.
On appeal, the Commonwealth Court acknowledged that psychological injury claims require proof of an “abnormal working condition” and that the analysis is highly fact-sensitive and specific to the claimant’s occupation.
In light of the standard, the Court held that the Workers’ Compensation Judge erred as a matter of law by concluding Ganley’s experience was normal.
The Court focused on the “specific factual scenario” Ganley faced: performing CPR on and witnessing the deaths of two infant children within 30 months. The Court rejected the employer’s argument that each component part — performing CPR or witnessing death — was normal in isolation. “We must consider the specific factual scenario faced by [Ganley], and we do not do so by looking to ‘unrelated component parts, where each part, standing on its own, might be safely determined to be a ‘normal’ working condition.’”
The Court emphasized that while firefighters operate in a high-stress environment, “certain events, even in high-stress professions, may rise to the level of abnormal working conditions.” Key facts supported this conclusion: in Ganley’s 20-year career prior to the first incident, he had never performed CPR on an infant; testimony indicated performing CPR on a child under five is “rare”; and two of the three times the township activated a Critical Incident Stress Team between 2018 and 2022 were for these specific incidents involving Ganley.
“[Ganley]’s development of disabling PTSD after the sequence was not a ‘subjective reaction to normal working conditions,’” the Court held. It concluded that “the compounded tragedy of twice having to attempt to resuscitate and witness the deaths of infant children within a [30-month] timespan” constituted an abnormal working condition as a matter of law. The case was remanded for calculation of benefits.
Ganley v. Upper Darby Township (Workers’ Compensation Appeal Board), 2025 WL 2967361 (Pa. Commw. Ct. Oct. 22, 2025).