In determining whether an employee's mental illness is work-related for purposes of obtaining workers' compensation, the reasonableness of the employer's conduct is not dispositive; the correct inquiry is whether the illness was caused by a condition of employment which is not generally inherent in every working situation. An Oregon appellate court reversed a Workers' Compensation Board's finding allowing an employee's claim for depression and remanded the case for consideration under the proper standard.

James Weathers was employed by the Department of Corrections. After an on-the-job back injury left him unable to perform his duties, he was reassigned to a new position. For two years he worked in an "underfilled" position, meaning that he did not have the requisite training or experience, but would learn on the job. He was then promoted to full status. Shortly thereafter, the Department announced that some employees would have to move to another facility, and consistent with the collective bargaining agreement, the decision would be based on seniority. A dispute developed over whether Weathers' two years in the underfilled position would count towards his seniority, despite the fact that under the collective bargaining agreement he was dearly entitled to credit for that time. Weathers became depressed and sought treatment from a psychiatrist.

He then filed a workers' compensation claim, which was rejected. On review, an administrative law judge set aside the rejection and allowed the claim, and that decision was affirmed by the Workers' Compensation Board. The Board identified the applicable test for whether a mental illness is work-related as being whether the illness was caused by a work condition not generally inherent in every working situation. The court concentrated on the unreasonableness of the employer's actions and found that since Weathers was entitled to the service time, the employer's actions were unreasonable.

On appeal, the court ruled that the Board properly identified the correct test, but applied it incorrectly. The court held that the reasonableness of the employer's action was not determinative. As long as the mental illness was related to a work condition not generally inherent in every work condition, the condition was work related, regardless of the employer's conduct.