Las Vegas POA

PTSD Caused Marital Problems, Not Vice-Versa

Written on 04/08/2021
Will Aitchison

Christopher Staford was a Crest Hill police officer in Illinois. He was working as a patrol officer on Decem­ber 11, 2010, when he and a suspect exchanged gunfire. During the inci­dent, Staford’s gun jammed. Shortly after the incident, Staford went to the emergency room, where he complained of feeling “rattled” and “very anxious.” He was diagnosed with anxiety. After continuing to experience symptoms, Staford began seeing Dr. Puls, a clin­ical psychologist, who diagnosed him with PTSD. Staford took three leaves of absence from the Crest Hill Police Department as a result of his PTSD symptoms in January 2011, November 2011, and November 2012.

In April 2014, Staford was placed on administrative leave while the Department conducted an internal investigation of his use of prescription narcotics. The Department sent Sta­ford to Dr. Samo to evaluate his fitness for duty. Upon accessing prescription records, Dr. Samo found that Staford obtained hydrocodone from multiple providers in large quantities. Staford told Dr. Samo that he had anxiety, difficulty sleeping, nightmares and irritability ever since the shooting incident of December 11, 2010. Dr. Samo diagnosed Staford with sub­stance dependence and PTSD.

Following the Department’s internal investigation, Staford volun­tarily resigned from his position. He filed an application for a line-of-duty disability pension with the Crest Hill Police Pension Fund and later amended his application to alternatively seek a non-duty disability pension. The Fund required Staford to be examined by three physicians, all three of whom initially found that Staford suffered from PTSD and was disabled as a result of the shooting on December 11, 2010.

One of the three doctors, Dr. Reff, submitted a supplemental report to the effect that Staford’s inability to per­form full and unrestricted police duties “had more to do with his inability to follow the codes of conduct that were required of him than to a psychiatric condition that developed due to a specific event while he was working for the City of Crest Hill.” Dr. Reff opined that Staford’s use of narcotic medication was not due to PTSD, and believed that the “precipitant” to a June 2016 hospitalization was not the December 11, 2010 incident but was Staford’s estranged wife becoming pregnant and moving in with the father of her child.

When the Fund’s Board denied Staford’s disability claim, he chal­lenged the decision in the Illinois Court of Appeals. In overturning the Fund’s denial, the Court used unusu­ally stern language.

The Court commented that “the Board’s rationale for denying Staford’s line-of-duty disability was that he had ‘recovered from the effects of the De­cember 11, 2010 incident.’ However, there was no medical testimony or ev­idence supporting this determination. Even Dr. Reff admitted that Staford continues to suffer from PTSD symp­toms as a result of the December 11, 2010 incident and opined that Staford’s ‘prognosis for sustained remission of symptoms is guarded to poor.’

“The Board seemed to rely on Dr. Reff’s conclusion that despite his PTSD, Staford ‘was able to successfully function full duty for extended periods of time from the date of the shooting until he ultimately stopped working.’ However, this opinion is not supported by the evidence. The record establishes that Staford took three separate leaves of absence of at least one month each from January 2011 to November 2012. While Staford did not take a leave of absence in 2013, he testified that he took off more than his allotted sick days because his PTSD symptoms made it unsafe for him to be at work.

“Finally, we find the Board’s determination that Staford’s 2016 hospitalization was not a result of his PTSD to be unsupported by the evi­dence. Relying on Dr. Reff’s opinion, the Board found the ‘precipitant’ of Staford’s June 2016 hospitalization to be marital problems, not the Decem­ber 11, 2010 incident. However, the Board’s conclusion ignores that PTSD has far-ranging effects and could have very well been the cause of Staford’s marital problems. The physicians treat­ing Staford during his hospitalization diagnosed him with both PTSD and major depressive disorder. The medical evidence, therefore, does not support the Board’s conclusion that Staford’s PTSD caused by the December 11, 2010 event had nothing to do with Staford’s 2016 hospitalization.

“Here, the Board’s conclusion that Staford was not suffering from PTSD that rendered him unable to perform his duties as a police officer was against the manifest weight of the evidence. We affirm the trial court’s order reversing the Board’s decision.”

Staford v. Board of Trustees, 2021 IL App (3d) 190779 (Ill. App. Ct. 2021).

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