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Edward E. Pool v. Lambert’s Point Docks, Inc.

Psychiatric injury claim under the Longshore Act defeated even though Claimant’s treating psychiatrist attributed Claimant’s ongoing disability and psychiatric illness to the cumulative stress of his workplace. The Benefits Review Board affirmed based on Marino v. Navy Exch. and held that psychiatric conditions which flow from legitimate personnel actions do not give rise to compensable injuries under the Longshore Act. This reverses the Board’s recent string of cases eroding the holding in Marino.

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