A recent appellate court decision has confirmed that a nurse’s post-traumatic stress disorder (PTSD) and major depressive disorder, developed while caring for COVID-19 patients, are compensable under workers’ compensation law. The ruling highlights the legal recognition of mental health impacts on healthcare workers during the early days of the pandemic.
The case was brought by Inova Alexandria Hospital and Inova Health System Foundation, who appealed an award granted by the Virginia Workers’ Compensation Commission to Courtney Santora. The appeal was decided by the Court of Appeals of Virginia on March 24, 2026, under Record No. 1837-24-2.
According to court documents, Santora worked as a registered nurse in a postoperative surgical unit at Inova Alexandria Hospital. When the COVID-19 pandemic began, her unit was converted to treat COVID-19 patients exclusively. This change shifted her duties from caring for healthy postsurgical patients to handling critically ill COVID-19 cases. Nurses in her unit also took on additional responsibilities such as housekeeping and maintenance to reduce staff exposure.
Santora testified that she had no prior experience providing respiratory care before being assigned these new duties. In April 2020, she contracted COVID-19 herself and required emergency treatment twice before quarantining for over three weeks due to symptoms including shortness of breath and extreme fatigue.
After returning to work in June 2020, Santora’s original unit resumed its previous functions but she continued to be “floated”—temporarily assigned—to other units treating COVID-19 patients. She sometimes spent entire 12-hour shifts with infected patients or split time between them and postsurgical cases. Despite expressing concerns about potentially exposing vulnerable postsurgical patients to the virus, these assignments continued.
On October 11, 2020, Santora suffered a panic attack after being assigned again to a COVID-19 unit; she was sent home by her supervisor. Ten days later, after another panic attack related to similar assignments, she requested but was initially denied a change in assignment before ultimately being switched by her supervisor so she could finish her shift.
Following these incidents, Santora sought medical attention from her primary care physician who diagnosed her with PTSD and referred her for psychiatric evaluation. Dr. Khin Myint diagnosed Santora with both PTSD and major depressive disorder linked directly to her April 2020 infection and work with COVID-19 patients without adequate personal protective equipment.
Further psychiatric treatment by Dr. Simona Pickboth concluded that Santora had ongoing anxiety with complex PTSD resulting from working with COVID-19 patients and determined she was unable to work. Medical records indicate persistent symptoms including flashbacks, lethargy, irritability, inability to focus, intrusive memories, and resistant depression requiring multiple treatments.
In March 2021, Santora sought emergency care at Calvert Health Medical Center for worsening anxiety and reported experiencing sadness, loss of interest or motivation, low energy, feelings of worthlessness or hopelessness—and suicidal thoughts since summer 2020.
From August 2021 onward Psychiatric Physician Assistant Natasha Olliver provided further care for Santora’s psychiatric conditions. Olliver diagnosed major depressive disorder, panic disorder, and chronic PTSD—stating there was “a direct causal connection between Santora’s work conditions during the COVID-19 pandemic and her diagnosis of PTSD.” Mental health therapist Tia Deloatch also attributed Santora’s acute mental distress specifically to being assigned repeatedly to intensive care units treating COVID-19 patients.
Santora filed a claim seeking lifetime medical coverage and total temporary disability benefits due to these mental health diagnoses. While an initial deputy commissioner found them not compensable under workers’ compensation law because they were not considered occupational diseases at first instance—the full Commission reversed this finding upon review after considering clear and convincing evidence presented regarding causation.
The Commission ultimately found that Santora was totally disabled from October 2020 onward due to occupational disease for about one year and four months between 2020–2023; partial disability applied thereafter but without entitlement due to failure in marketing remaining work capacity during that period.
Inova appealed on two grounds: first—that it was erroneous for the Commission to find that PTSD and major depressive disorder arose out of employment; second—that it erred in finding those conditions resulted specifically from caring for COVID-19 patients as part of nursing duties. Both arguments centered on whether these mental health issues qualified as compensable ordinary diseases of life under Virginia law (Code §65.2-401).
The appellate panel noted that credible evidence supported the Commission’s findings: testimony from Santora herself described how witnessing death among severely ill patients affected her mental health; medical providers corroborated this link through their diagnoses attributing PTSD directly to workplace exposure during the pandemic response.
Ultimately the Court affirmed the Commission’s judgment stating: “the record supports the Commission’s conclusion that Santora’s PTSD and major depressive disorder are compensable ordinary diseases of life arising out of…her work as a nurse caring for COVID-19 patients.”
Attorneys listed in filings include Nirav Patel (Franklin & Prokopik P.C.) representing appellants Inova Alexandria Hospital et al., while Corey R. Pollard (Jenkins Block & Associates P.C.) represented appellee Courtney Santora. The case is identified as Record No. 1837-24-2.
Source: 1837242_Inova_Alexandria_Hospital_v_Santora_Opinion_Virginia_Court_of_Appeals.pdf
