The Supreme Court of Ohio has upheld the constitutionality of a legal provision that denies state workers' compensation benefits for job-related psychiatric or psychological conditions unless the mental condition results from a compensable physical injury or occupational disease. The decision reversed lower court decisions, which had held that language excluding purely psychological conditions from the definition of workplace injuries eligible for compensation violated the United States and Ohio constitutions.

The case involved Canton bank teller Kimberly McCrone, who was diagnosed with "adjustment reaction and post-traumatic stress disorder" as a result of a confrontation with an armed robber in an August 2001 robbery at her place of employment. McCrone suffered no physical injuries in the incident. She applied for workers' compensation benefits from her employer, Bank One. The employer denied her claim based on a provision in the Ohio workers' compensation statute that specifically excludes psychiatric conditions from the definition of compensable injuries, except when the condition arises from a job-related physical injury or disease.

McCrone's attorneys argued that the provision should be struck down because it violated the "equal protection" provisions in the 14th Amendment of the U.S. Constitution and the Ohio Constitution.