PENNSYLVANIA WORKERS’ COMPENSATION
CASE SUMMARIES
07/1/2025 – 07/31/2025
JUDICIAL DISCRETION
Prospect Medical Holdings v. Susan Lewis (WCAB)
Commonwealth Court of Pennsylvania – Unpublished Memorandum Opinion
Decided: July 21, 2025
Issues:
Whether the WCJ’s determination that Claimant suffered a work-related rotator cuff tear was based upon substantial competent evidence; Whether the WCJ erred and abused her discretion by denying the Termination Petition and by awarding total disability benefits?
Background:
Claimant was employed by Employer, where she worked in the emergency department, when she injured her left shoulder while assisting a patient. On March 13, 2021, Employer issued a Medical Only Notice of Temporary Compensation Payable (Temporary Notice), which acknowledged that Claimant had suffered a strain or tear in her left shoulder. Claimant was put on light duty. While Claimant’s forearm pain quickly improved, her shoulder issues remained. Eventually, she was released to full work duty on April 23, 2021, whereupon she returned to her pre-injury position. Claimant subsequently resigned and moved to Mississippi in July 2021, where she began working as a registered nurse. Upon her arrival in Mississippi, she was unable to find practitioners who would accept her private insurance or her Pennsylvania workers’ compensation coverage; as a result, she received no treatment for her shoulder injury for roughly 10 months after her relocation. Claimant eventually resigned from the new employment on March 24, 2022, in lieu of termination, due to the fact that she was physically unable to perform her job duties. She then returned to Pennsylvania, had rotator cuff surgery, and then returned to Mississippi after a brief period of convalescence, where she began receiving post-operative physical therapy. In 2022, Claimant filed a Review Petition, requesting that the description of her injury be amended to specifically state that she had suffered a left rotator cuff tear. She then filed a Claim Petition on July 22, 2022, through which she sought total disability benefits for her injury. Prospect then filed a Termination Petition on September 23, 2022, in which it alleged that Claimant had fully recovered from her injury as of September 2, 2022, based upon an independent medical evaluation. The WCJ granted the Claim and Review Petitions and denied the Termination Petition. The Board affirmed.
Holding:
The record supports the WCJ’s determination that Claimant established that she suffered a work-related left rotator cuff tear on March 2, 2021. To the extent that findings were based on substantial record evidence, the WCJ did not capriciously disregard evidence regarding the cause and nature of Claimant’s shoulder injury. However, the Court was persuaded by Employer’s second argument, as the WCJ did not properly justify her denial of the Termination Petition. Further, as with the Termination Petition, the WCJ failed to address the certain factual ambiguities before disposing of the Claim Petition. The Court felt that there were two important questions that still needed to be addressed. First, did Dr. Abboudi’s opinion that Claimant was unable to return to work as of August 26, 2022, encompass all duties which she could have performed at employer, post-operatively, or was that opinion based upon his lack of awareness regarding her eligibility to perform light or sedentary duties at Employer? Second, would Employer have potentially allowed Claimant to perform light duty at Employer until she received full post-surgical medical clearance to return to her regular duties and, if so, what would she have had to show at her 90-day reevaluation in order to secure such dispensation? Without answers to these questions, the Court could not determine whether the WCJ properly concluded that Claimant was fully disabled as of May 6, 2022, whether the WCJ also correctly determined that Claimant was entitled to total disability benefits in the amount of $786.43 per week, or whether Claimant had fully recovered from her surgery as of September 2, 2022. A remand is therefore necessary, so that these questions can be adequately answered. The Board’s order was affirmed in part, to the extent that order affirmed the WCJ’s Decision to grant Claimant’s Review Petition. The Court vacated the Board’s order in part, to the extent the order affirmed the WCJ’s Decision to grant the Claim Petition and deny Employer’s Termination Petition; and remanded in part to the Board, with instructions that the Board further vacate the WCJ’s Decision in part, as to the WCJ’s granting of the Claim Petition and denial of Prospect’s Termination Petition. The Court further directed the Board to instruct the WCJ to properly determine on remand whether Claimant was totally disabled, as well as the duration of any such total disability, and whether Lewis had fully recovered from surgery on her left rotator cuff as of September 2, 2022.
Affirmed, in part, Vacated, in part, and Remanded.
Barbara Lynch v. Downs Racing, LP (WCAB)
Commonwealth Court of Pennsylvania – Unpublished Memorandum Opinion
Decided: July 28, 2025
Issue:
Whether the WCJ’s decision is supported by substantial evidence?
Background:
Claimant worked as a floor manager in Employer’s casino. Claimant sustained a work-related injury after falling and landing on her knee. Employer accepted liability for Claimant’s knee injury by a Notice of Compensation Payable (NCP). Employer filed a Suspension Petition and two Termination Petitions asserting Claimant was fully recovered and able to return to work as of May 9, 2022. Claimant filed a Review Petition requesting an expansion of her injury description to include low back and right sacroiliac (SI) joint injuries sustained as a result of her fall at work. After receiving evidence, the WCJ found that the Employer proved Claimant had fully recovered from any work-related injury to her back and right knee. Further, the WCJ indicated Employer established Claimant was capable of returning to employment at her pre-injury position Employer offered to her, which she refused to accept. Thus, the WCJ granted Employer’s Suspension Petition and Termination Petitions, and denied and dismissed Claimant’s Review Petition. The Board affirmed the WCJ’s Decision, but modified Claimant’s injury description to include a lumbar strain, which was fully recovered.
Holding:
Whether the record contains evidence to support findings other than those made by the WCJ is irrelevant; the critical inquiry is whether the record supports the findings the WCJ actually made. The record supported the WCJ’s rejection of testimony relating Claimant’s SI joint injury and treatment to her fall at work, and testimony regarding Claimant’s inability to return to work. Because substantial evidence supported the WCJ’s findings, there is no basis on which the Court could reverse the WCJ’s conclusion that Claimant suffered no injuries beyond her accepted work injuries. To the extent Claimant seeks to have this Court reweigh the evidence, we decline to do so because the WCJ has the sole authority to assess credibility, resolve conflicting evidence, and determine the weight to give the evidence. The WCJ properly determined Claimant did not meet her burden of proving her accepted work injury should be expanded to include a right SI joint injury and denied her Review Petition. Additionally, the WCJ properly determined Employer met its burden of proving Claimant’s disability ceased because her physical ability improved and granted Employer’s Suspension Petition and Termination Petitions.
Affirmed.
Delia Nagy v. Medplast Engineered Products (WCAB)
Commonwealth Court of Pennsylvania – Unpublished Memorandum Opinion
Decided: July 10, 2025
Issue:
Whether the WCJ’s decision is in error in requiring expert medical testimony?
Background:
Claimant filed a Claim Petition alleging that she sustained a work-related injury on April 24, 2020, in the nature of shortness of breath, fatigue, muscle aches, nausea, diarrhea, and headache. Later, Claimant amended the Claim Petition to include injuries to her chest, back, and arms occurring as a result of workplace exposure to toxic chemicals as well as repetitive lifting. The WCJ denied the Claim Petition. The WCJ pointed out that Claimant presented no medical testimony relating her symptoms to workplace chemical exposure or any other kind of work event. The Board affirmed.
Holding:
There is nothing in the record to suggest the existence of a causal nexus between Claimant’s work duties and the ailments listed in the Claim Petition, such as shortness of breath, fatigue, muscle aches, nausea, diarrhea, and headache. To the contrary, the employer’s expert explained credibly that, to the extent Claimant suffers any breathing difficulties at all, they were obviously caused by her smoking-related emphysema rather than any work duties. In the instant matter, Claimant’s own treating physicians failed to reach a conclusion that her symptoms were work-related. Since it has never been obvious in this case that Claimant suffered a disabling, work-related pulmonary injury, the establishment of the causal relationship required unequivocal medical evidence, which Claimant has not presented. Claimant failed to carry the burden of proving that she sustained a work-related injury. Since the causal connection between her lingering symptoms and her work duties was not obvious, Claimant was required to present unequivocal medical evidence establishing that connection.
Affirmed.
IMPAIRMENT RATING EVALUATIONS
Joseph Barrios v. City of Philadelphia (WCAB)
Commonwealth Court of Pennsylvania – Unreported Memorandum Opinion
Decided: July 11, 2025
Issue:
Whether Act 111 can be constitutionally applied to workers whose injuries occurred before October 24, 2018, the effective date of Act 111?
Background:
Claimant challenges as unconstitutional the retroactive application of Act 111 of 2018, which added Section 306(a.3) of the Workers’ Compensation Act (Act), altering the criteria for determining a claimant’s disability status; providing that an impairment rating of less than 35% constitutes a partial disability; and providing a credit for partial disability benefits already paid. The WCJ issued a decision granting a modification of Claimant’s benefits from TTD status to TPD status as of March 17, 2022. The Board affirmed.
Holding:
Based on established case law, the Court concluded that Claimant’s challenges to the constitutionality of Act 111 have already been addressed and rejected by Commonwealth Court. Act 111 is not unconstitutional either on its face or as applied to claimants injured prior to its effective date, so long as the IRE does not pre-date Act 111. Claimant’s IRE was performed on March 17, 2022, which is more than three years after Act 111’s effective date, and therefore Act 111 applies and does not abrogate any vested rights. Additionally, the plain language of Act 111 provides that the 104-week provisions are to be given retroactive effect. The WCJ did not err in granting Employer’s Modification Petition under Act 111 and modifying Claimant’s benefit status from TTD to TPD based upon the IRE.
Affirmed.
Khalda Bibi v. Ross Dress for Less (WCAB)
Commonwealth Court of Pennsylvania – Unreported Memorandum Opinion
Decided: July 16, 2025
Issue:
Whether the WCJ’s findings of fact were supported by substantial evidence?
Background:
Claimant filed a claim petition asserting that she was injured in the course of her employment as a packer with Employer, while carrying heavy boxes. Specifically, the claim petition alleged that Claimant sustained a right knee contusion and an L5-S1 disc bulge that caused lumbar radiculopathy. Based upon credibility findings, the WCJ concluded that Claimant was fully recovered from the work injury. The WCJ awarded Claimant medical benefits through April 4, 2023. The WCJ did not award disability compensation because her injury did not cause her to be off work in excess of seven days, the minimum necessary to be eligible for disability benefits. The Board affirmed.
Holding:
However, the WCJ’s mistake about the medical notes is, at most, harmless error. An error is harmless if it “is not necessary to the adjudication.” The WCJ’s finding on the duration of Claimant’s disability is supported by substantial evidence. It was Claimant’s burden to show that she was unable to work because of the work injury. Notwithstanding the WCJ’s error in summarizing certain testimony, the credited testimony established that Claimant was able to return to work four days after sustaining her work-related contusion injury.
Affirmed.
REINSTATEMENT OF BENEFITS
TOLLING THE LIMITATIONS PERIOD
Pablo Munoz v. Jermacans Style (WCAB)
Commonwealth Court of Pennsylvania – Unpublished Memorandum Opinion
Decided: July 11, 2025
Issue:
Whether the Board erred in affirming the WCJ’s decision regarding the time bar, as his filing of the initial reinstatement and the following petitions were timely, even if dismissed, and should serve to toll the statute of limitations?
Background:
Claimant sustained a work-related injury, which his employer accepted. Subsequently, Employer filed a petition to terminate Claimant’s benefits following an independent medical examination (IME) of Claimant. Claimant did not file an answer in opposition to the petition and did not appear either in person or via counsel at the hearing or otherwise defend against the allegations. At the hearing, the WCJ accepted the report of Employer’s IME doctor without objection. Based on this evidence alone, the WCJ determined that Claimant was fully recovered as of that date and granted the termination petition. Claimant did not appeal the WCJ’s decision. Sometime later Claimant filed a reinstatement petition and a penalty petition asserting that his benefits should be reinstated because the termination petition was not properly granted because it was not based on substantial, competent evidence. Claimant also asserted that Employer violated the Act by the stoppage of benefits. These petitions also were denied by the WCJ, who concluded that the prior order terminating his benefits was final and binding on Claimant because it was not appealed and that Claimant was barred by res judicata from asserting that the termination was improper based on the evidence presented. The Board affirmed. A few years later, the Claimant filed another reinstatement petition and penalty petition, asserting that the termination order was not supported by substantial evidence and was void ab initio because only the IME doctor’s report was admitted into evidence, and not his testimony. These petitions were also denied based on technical res judicata because the initial WCJ decision terminating Claimant’s benefits was a final judgment that was not appealed. The Board affirmed. Finally, in 2023, Claimant filed the present Petitions seeking the review and/or reinstatement of his benefits based on a purported incorrect description of his September 18, 2018 work-related injury, and because his disability arising from that work-related injury had recurred and worsened as of March 20, 2019. The WCJ found that the most recent payment of compensation made prior to the filing of Claimant’s pending petitions was June 6, 2019. Therefore, the WCJ found that Claimant’s Reinstatement and Review Petitions were time-barred. The petitions were denied and the Board affirmed.
Holding:
The limitations period was not tolled. Where a Claimant seeks to add a distinct, consequential injury to the NCP, and to reinstate his indemnity payments for disability related thereto, under Section 413(a) of the Act, he had to file the petitions within three years of the date of the most recent compensation payment. Because Claimant did not file his Reinstatement Petition within the requisite three years of his most recent compensation payment, the Board did not err in affirming the WCJ’s decision denying the Instant Petitions.
Affirmed.
SUFFICIENCY OF CREDIBILITY DETERMINATIONS
Layne Sabo v. Johnstown Wire Technologies, et al. (WCAB)
Commonwealth Court of Pennsylvania – Unpublished Memorandum Opinion
Decided: July 15, 2025
Issue:
Whether the Board erred in affirming the WCJ’s determination that Claimant did not carry his burden to establish that his disabling injury, a right shoulder dislocation and anterior labral tear, was causally related to the work incident?
Background:
Claimant suffered a right shoulder or upper arm injury while pulling wire out of a machine in the course and scope of his employment with Employer. In a petition, The WCJ ultimately credited Claimant’s testimony that, as a result of the March 6, 2021 work incident, he suffered the onset of pain at the top of his right arm where it connects to his shoulder. The WCJ credited Claimant’s medical testimony establishing that he was unable to work due to a right shoulder dislocation and anterior labral tear, the WCJ further found that those injuries were not causally related to his work with Employer and, therefore, were not compensable. Instead, the WCJ found that only an unspecified right upper arm or shoulder injury was compensable and that Employer was responsible only for the costs of medical treatment rendered on the day of injury. The Board affirmed.
Holding:
If the WCJ found, that some intervening event gave rise to Claimant’s disability, it nevertheless may still be compensable if it is the natural and probable consequence of the non-disabling work incident. The WCJ made no findings in this respect. This was error. Moreover, the WCJ’s crediting, employer’s expert’s testimony over that of Claimant’s does not resolve this question, and the Board erred in concluding to the contrary. The WCJs findings and credibility determinations regarding causation are limited to a determination that the dislocation and anterior labral tear did not occur at work. The WCJ made no findings or credibility determinations with regard to whether the work incident, with or without intervening events or circumstances, in fact caused the disabling injury. This was particularly significant here given the undisputed facts that Claimant’s right shoulder pain was constant and increasingly severe after his work injury, the dislocation symptoms manifested only 45 minutes later, and Claimant engaged in no intervening strenuous activities. A remand for specific findings and credibility determinations was warranted. The Court affirmed that portion of the Board’s order affirming the WCJ’s findings and conclusions regarding whether Claimant’s disability occurred at work. The Court vacated that portion of the Board’s order that affirmed in total the WCJ’s determination of causation and remanded the matter for the WCJ to make additional findings and conclusions on that issue.
AFFIRMED, in part, and VACATED, in part, and REMANDED.
EVIDENCE PROPERLY PART OF THE RECORD
Alvin Sewell v. United Parcel Service (WCAB)
Commonwealth Court of Pennsylvania – Unreported Memorandum Opinion
Decided: July 10, 2025
Issue:
Whether the WCJ erred by relying on the deposition testimony of Employer’s medical expert, Dr. Kann, because the list of exhibits in the WCJ’s decision indicates that Dr. Kann’s deposition transcript was not admitted into evidence nor part of the certified record?
Background
The WCJ credited the testimony of Dr. Kann in granting a termination petition. While the WCJ extensively discussed the testimony of Dr. Kann and relied upon that testimony in granting the termination petition, the list of exhibits in the WCJ’s decision indicates that Dr. Kann’s deposition transcript was not admitted into evidence.
Holding:
Items which are not part of the record may not be considered by the fact-finding tribunal, or the appellate body on review. Because the only evidence Employer presented with respect to its termination petition was the deposition testimony of Dr. Kann, the admission status of that testimony was critical. An administrative agency may, on its own motion, correct typographical, clerical and mechanical errors, as well as undisputed factual errors and factual misconceptions, provided proper notice and explanation is given. However, Section 413 does not apply where correction of the alleged error requires additional findings of fact or conclusions of law, or a change in the WCJ’s factual or legal analysis. The WCJ’s failure to list Dr. Kann’s deposition transcript as an admitted document is merely an administrative oversight. As no further hearings were held, there was not an opportunity for Employer to formally move the transcript into evidence. More importantly, the WCJ discussed Dr. Kann’s testimony extensively in his decision, and clearly relied upon it in granting Employer’s termination petition. However, the Board should have remanded the case to the WCJ to fix the issue, rather than simply considering the deposition testimony as admitted evidence. This was error, and the Court could not conduct proper appellate review of the decision to grant Employer’s termination petition without access to Dr. Kann’s testimony. The Court remanded the case to the Board for a remand to the WCJ to correct the omission. The Court affirmed, in part, the Board’s order with respect to the notice issue, and remanded the case solely to correct the record as to Dr. Kann’s deposition transcript. The corrected record was ordered to be sent to the Court within 30 days, and the Court retained jurisdiction.
Remanded
CHALLENGE TO WITNESS COMPETENCY
Brandon Bonanno v. Rosebud Mining Company (WCAB)
Commonwealth Court of Pennsylvania – Unpublished Memorandum Opinion
Decided: July 22, 2025
Issue:
Whether Claimant has preserved a challenge to an Expert’s legal competency, on an IRE, as to psychiatry or psychology?
Background:
Claimant was working for Employer as an underground coal miner when a piece of equipment struck him in the back, pinning him to the floor. Employer issued a Notice of Temporary Compensation Payable. In June of 2019, the parties by agreement expanded the work injury to include anxiety, later expanded further to include PTSD. Later, Employer filed a Modification Petition seeking to change Claimant’s disability status to partial based upon an IRE which assigned Claimant a whole-person impairment rating of 12 percent. At his deposition, the IRE reviewer testified that he is Board certified in physical medicine and rehabilitation, spinal cord injury medicine, and independent medical examinations (IMEs). Counsel for Claimant did not object to the witnesses’ competency to testify during voir dire. The WCJ granted Employer’s Modification Petition and changed Claimant’s disability status to partial disability. The Board affirmed.
Holding:
Objections to a witness’ competency to testify at the deposition are waived if they are not raised before or during the deposition where the ground for the objections are known to the objecting party. Counsel for Claimant clearly stated at the deposition that he had no objection to the IRE reviewer’s qualifications to testify as an expert or to the admission of his deposition testimony into evidence. Therefore, because Claimant failed to preserve his objection to competency to testify regarding his psychological condition, the issue is waived. A claimant may introduce his own evidence during modification proceedings concerning his degree of impairment to challenge the IRE findings made by the performing physician. Here, Claimant offered no evidence whatsoever to challenge the IRE reviewer’s application of the AMA Guides or method of calculating his whole-person impairment rating. Therefore, Claimant has waived his challenge to Dr. Wolk’s competency to testify.
Affirmed.
REQUEST FOR CONSOLIDATION OF COMMONWEALTH COURT APPEALS
Billy Miller, III v. Integrity Staffing Solutions (WCAB)
Commonwealth Court of Pennsylvania – Unpublished Memorandum Opinion
Decided: July 28, 2025
Issue:
Whether the Claimant’s request for consolidation of two separate matters pending before the Commonwealth should be granted?
Background:
Claimant, acting pro se, petitioned for review from the order of the Board reversing the order of the WCJ which granted Claimant’s reinstatement and review petitions. Claimant also filed an application to consolidate this case with a later-filed appeal from the Board’s order affirming the WCJ’s denial of Claimant’s request for recusal. They affirmed with respect to the Board’s reversal of the WCJ’s decision to grant Claimant’s reinstatement and review petitions and denied Claimant’s application to consolidate the cases.
Holding:
First, the Claimant did not introduce competent medical evidence. Thus, he could not meet his burden to show that his injury recurred or that his injury description should be expanded. Further, the request to consolidate Miller 2023 and Miller 2024, is governed by Pennsylvania Rule of Appellate Procedure 513. Where there is more than one appeal from the same order, or where the same question is involved in two or more appeals in different cases, the appellate court may, in its discretion, order them to be argued together in all particulars as if but a single appeal. Appeals may be consolidated by stipulation of the parties to the several appeals. However, the Court noted that, between the matters, there is no commonality in the orders appealed. Miller 2023 appeals the Board’s order reversing the WCJ’s order granting Claimant’s reinstatement and review petitions and Miller 2024 appeals the Board’s order affirming the WCJ’s order denying Claimant’s request to recuse in further litigation after the Board’s earlier final order. Further, the alleged bias of the WCJ in the later (Miller 2024) matter was not properly before the Court with respect to Miller 2023.
Affirmed and Request for Consolidation Denied.
PETITION FOR ALLOWANCE OF APPEAL TO THE PA SUPREME COURT – GRANTED
Wegmans Food Markets v. Bonnie Cole (WCAB)
Supreme Court of Pennsylvania.
July 23, 2025
The Petition for Allowance of Appeal was granted, limited to the issues set forth below. Allocatur is DENIED as to all remaining issues. The issues, as stated by petitioner, are:
(1) Under the provisions of Section 306(f.1)(8) of the Workers’ Compensation Act [77 P.S. § 531(8)] regarding forfeiture of benefits due to a claimant’s refusal of reasonable medical services, do the terms “medical services” and “services rendered by physicians or other health care providers” include reasonable medical “advice”?
(2) Pursuant to the forfeiture provisions of the Workers’ Compensation Act, in order for medical services to be “reasonable,” must the medical services provided to an injured claimant result in physical improvement of an injury or an increase in prospects for a return to gainful employment; or is it sufficient to prove that the services would aid in healing and/or prevent deterioration of the claimant’s condition?
PENNSYLVANIA LEGISLATIVE REVIEW
House Bill 183
A few months ago, the Commonwealth of Pennsylvania, House L&I Committee, voted on what is now designated as HB 183. This Bill expands access to workers compensation disfigurement benefits by increasing the duration of eligibility from up to 275 weeks to a new level of up to 400 weeks, extending the benefit to the entire body, and not just to the head, face and neck, and allowing these benefits to be paid simultaneously with indemnity benefits. The bill was passed by the House on April 7, 2025, and has now been referred to the Senate Labor & Industry Committee. It remains with this committee. It is worthy of note that this bill was amended, just prior to passage, to apply to injuries for which “permanent disfigurement was reached” after the effective date of the provision, whereas it was previously intended to only apply to injuries sustained on or after the effective date. As of today, there has been no new action.
NEW JERSEY WORKERS’ COMPENSATION
CASE SUMMARIES
7/1/2025 – 7/31/2025
NEW JERSEY LEGISLATIVE UPDATE
Assembly Bill 4750
Expands certain employer reporting requirements to include entities that employ or contract with individuals for financial compensation, including ridesharing and delivery technology platforms.
Last Action: January 14, 2025 – Received in the Senate, Referred to Senate Labor Committee
Assembly Bill 2100/S1470
Provides workers’ compensation benefits for certain public safety workers who developed illness or injury as result of responding to September 11, 2001 terrorist attacks.
Last Action: September 19, 2024 – Reported out of Asm. Comm. With Amendments, and referred to Assembly Public Safety and Preparedness Committee
Assembly Bill 5198/S3772
Concerns valuation of board and lodging with respect to workers’ compensation.
Last Action: January 23, 2025 – Reported and Referred to Assembly Appropriations Committee
Senate Bill 794
Concerns workers’ compensation insurance requirements for certain corporations and partnerships.
Last Action: December 5, 2024 – Reported from Senate Committee as a Substitute, 2nd Reading
Assembly Bill 5792/ S4590
Provides for workers’ compensation coverage of certain counseling services for first responders and provides that certain mental health related communications are confidential.
Last Action: June 30, 2025 – Passed Senate (passed both houses)
Result: Employers of first responders are required to pay for up to 12 hours of paid confidential counseling compensable under the provisions of the worker’s compensation law for a first responder who experiences a critical incident in the course and scope of the first responder’s employment. The first responder can select the mental health professional to provide counseling. If the mental health professional determines the first responder needs more than 12 hours of counseling, the Employer is required to pay for up to an additional 24 hours of counseling. Critical incident includes events such as firing a weapon, being involved in an exchange of gun fire, receiving a serious bodily injury, witnessing certain serious bodily injuries and deaths, and being involved in certain investigations related to minors.
