WCAB

Pacific Gas & Electric Company (PG&E) contends the Workers’ Compensation Appeals Board (WCAB) erred when it awarded benefits to respondent Clifford Bryan for work-related psychiatric injury. In analyzing this claim, we must determine whether the circumstances cited by the WCAB constitute “events of employment” under Labor Code section 3208.3, subdivision (b)(1) . We conclude that some of the factors relied on by the WCAB were inappropriate. Employee stress that results from fluctuations in the value of an employer’s stock or from uncertainty about an employer’s future in the face of a downturn in the employer’s business is not a compensable event of employment under the Labor Code. Accordingly, we will annul the WCAB’s decision and remand for further proceedings.

I. FACTUAL AND PROCEDURAL BACKGROUND

The tumultuous deregulation of California’s utility industry and the related uncertainty about PG&E’s financial health provide the backdrop for this case. Respondent Bryan had worked for PG&E for over 30 years. He started as a meter reader and eventually became a “collector.” As a “collector” he went to the homes of delinquent customers to either collect money or turn off…