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Inova Alexandria Hospital v. Courtney Santora - Workers' Compensation

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Filed March 24th, 2026
Detected March 24th, 2026
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Summary

The Virginia Court of Appeals affirmed a Workers' Compensation Commission award to a nurse for PTSD and major depressive disorder. The court found these conditions to be compensable ordinary diseases of life arising from her employment caring for COVID-19 patients.

What changed

The Virginia Court of Appeals affirmed a decision by the Virginia Workers' Compensation Commission awarding benefits to Courtney Santora, a nurse, for PTSD and major depressive disorder. The court found that these conditions were compensable ordinary diseases of life arising out of her employment, specifically related to her care for COVID-19 patients during the pandemic. The court rejected Inova Alexandria Hospital's argument that the conditions were not work-related.

This ruling confirms that healthcare providers suffering from mental health conditions directly linked to their work, particularly during public health crises like the COVID-19 pandemic, are eligible for workers' compensation benefits. Employers in the healthcare sector should review their policies and procedures regarding employee mental health support and the compensability of work-related psychological conditions. While this is a specific case, it reinforces the importance of recognizing and addressing the occupational risks associated with frontline healthcare work.

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March 24, 2026 Get Citation Alerts Download PDF Add Note

Inova Alexandria Hospital v. Courtney Santora

Court of Appeals of Virginia

  • Citations: None known
  • Docket Number: 1837242
  • Precedential Status: Non-Precedential
  • Disposition: Finding affirmed as Commission did not err awarding claim for total temporary disability and medical benefits for PTSD and major depressive disorder finding conditions are compensable ordinary diseases of life arising out of employment as nurse caring for COVID-19 patients; credible evidence in record supports findings

  • Opinion

  • Authorities (6)

  • Cited By (0)

  • Summaries (0)

  • Similar Cases (50.8K)

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Disposition

Finding affirmed as Commission did not err awarding claim for total temporary disability and medical benefits for PTSD and major depressive disorder finding conditions are compensable ordinary diseases of life arising out of employment as nurse caring for COVID-19 patients; credible evidence in record supports findings

Combined Opinion

COURT OF APPEALS OF VIRGINIA

Present: Judges Causey, Chaney and White
UNPUBLISHED

INOVA ALEXANDRIA HOSPITAL, ET AL.
MEMORANDUM OPINION *
v. Record No. 1837-24-2 PER CURIAM
MARCH 24, 2026
COURTNEY SANTORA

FROM THE VIRIGNIA WORKERS’ COMPENSATION COMMISSION

(Nirav Patel; Franklin & Prokopik, P.C., on brief), for appellants.

(Corey R. Pollard; Jenkins, Block, & Associates P.C., on brief), for
appellee.

Inova Alexandria Hospital and Inova Health System Foundation (collectively, “Inova”)

appeal the Workers’ Compensation Commission’s award to Courtney Santora. The award

compensates Santora for the PTSD and major depressive disorder that she incurred arising from

her employment as a nurse during the early days of the COVID-19 pandemic. Inova argues that

the Commission erred in finding that Santora’s diagnosed conditions are compensable ordinary

diseases of life arising out of her employment. Finding no error, we affirm the Commission’s

judgment. 1

*
This opinion is not designated for publication. See Code § 17.1-413(A).
1
Having examined the briefs and record in this case, the panel unanimously agrees that
oral argument is unnecessary because “the facts and legal arguments are adequately presented in
the briefs and record, and the decisional process would not be significantly aided by oral
argument.” See Code § 17.1-403(ii)(c); Rule 5A:27(c).
BACKGROUND 2

Santora worked as a registered nurse in a postoperative surgical unit for general surgeries

and orthopedics at Inova Alexandria Hospital. When the pandemic began, her unit was

converted to treat COVID-19 patients. As a result, Santora’s work duties shifted from caring for

healthy postsurgical patients to caring exclusively for COVID-19 patients. The nurses also had

to handle other responsibilities—including housekeeping, maintenance, and IT—in an effort to

reduce the number of people on the floor. On several occasions, Santora was required to escort

patients to the intensive care unit for intubation to ensure that the nurse receiving the patient

received the report. Santora testified that she had no prior experience providing respiratory care.

In April 2020, Santora contracted COVID-19 and twice sought emergency department

treatment. She quarantined for about three and a half weeks, during which she “experienced

shortness of breath, cough[ing], extreme fatigue, heart racing, and night sweats.” In June 2020,

Santora’s unit resumed its prior postoperative surgical functions. However, Santora was

regularly “floated” to other units to assist with the care of COVID-19 patients. While “floating,”

Santora sometimes treated COVID-19 patients for an entire 12-hour shift. Other times, she

would treat them for part of a shift, after which she would return to her postsurgical patients.

Santora expressed concern about exposing postsurgical patients to COVID-19, but despite her

concerns, these “float” assignments to COVID-19 units continued.

On October 11, 2020, Santora suffered a panic attack in the hallway after being assigned

to a COVID-19 unit. Santora’s supervisor sent her home. Ten days later, Santora experienced a

second panic attack after being assigned to float to a COVID-19 unit. Santora asked for a change

2
“On appeal from a decision of the Workers’ Compensation Commission, the evidence
and all reasonable inferences that may be drawn from that evidence are viewed in the light most
favorable to the party prevailing below.” Anderson v. Anderson, 65 Va. App. 354, 361 (2015)
(quoting Artis v. Ottenberg’s Bakers, Inc., 45 Va. App. 72, 83 (2005) (en banc)).
-2-
in assignment, which was denied by the nurse in charge. Santora then called her supervisor, who

switched her assignment, and Santora finished her shift.

After the second panic attack, Santora sought medical attention from her primary care

physician, who diagnosed her with PTSD and referred her for psychiatric treatment. Dr. Khin

Myint performed a psychiatric evaluation of Santora and diagnosed her with PTSD and major

depressive disorder resulting from her April 2020 COVID infection and her work with COVID

patients without adequate personal protective equipment.

Santora’s PTSD and depression were treated by Dr. Simona Pickboth at Dominion

Hospital. Dr. Pickboth concluded that Santora had “ongoing anxiety with complex PTSD” from

working with COVID-19 patients, leaving Santora unable to work. Santora continued to suffer

from flashbacks, lethargy, irritability, and an inability to focus, intrusive memories, and she

sought multiple treatments for her “resistant depression.”

In March 2021, Santora sought emergency treatment at Calvert Health Medical Center

for worsening anxiety. She reported suffering from “sadness, loss of interest, loss of motivation,

low energy, feeling worthless, hopeless[ness], helpless[ness,] and suicidal thoughts” since the

summer of 2020.

Starting in August 2021, Psychiatric Physician Assistant Natasha Olliver provided

Santora’s psychiatric care. Santora told Olliver that she was unprepared to handle “severely ill

patients and death” in the COVID-19 unit. Santora reported that after caring for COVID-19

patients, “she developed a low mood, sleep trouble, decreased energy, and anhedonia.” 3 Olliver

diagnosed Santora with major depressive disorder, panic disorder, and “chronic” PTSD. Olliver

determined that “Santora’s PTSD followed as a natural incident of her work as a nurse from the

3
Olliver noted in early 2022 that Santora’s symptoms worsened over time, including
increased suicidal ideation, hopelessness, nightmares, and flashbacks.
-3-
workplace exposure to sick and dying COVID patients” and found “a direct causal connection

between Santora’s work conditions during the COVID-19 pandemic and her diagnosis of

PTSD.”

Santora’s mental health therapist, Tia Deloatch, also concluded that Santora’s work with

COVID-19 patients caused her “acute mental distress,” including “recurrent and distressing

recollections of the events, including images, thoughts and perceptions.” Deloatch noted that

Santora’s “diagnosis of PTSD is specific and related to her being assigned to the COVID”

intensive care unit. 4

Santora filed a claim for a lifetime medical award and total temporary disability resulting

from her PTSD and major depressive disorder. The deputy commissioner found that her

diagnoses were not compensable. On review, however, the full Commission reversed, finding

“by clear and convincing evidence” that Santora’s PTSD and major depressive disorder were

compensable diseases. The Commission remanded the case to the deputy commissioner to

determine Santora’s award. The deputy commissioner found that Santora was totally disabled

from October 2020 to the present and awarded her compensation. The Commission affirmed in

part and reversed in part. 5 Inova appeals.

ANALYSIS

Inova assigns two errors to the Workers’ Compensation Commission. First, that the

Commission erred by finding that Santora incurred PTSD and major depressive disorder “as

4
Santora had a preexisting history of anxiety treatment since 2013 or 2014, but she had
not been diagnosed with either PTSD or major depressive disorder until after her panic attacks.
5
The Commission also found that Santora was totally disabled and entitled to
compensation due to her occupational diseases for a total of about a year and four months
between 2020 and 2023. For the remainder of the period, the Commission found that Santora
was partially disabled, but failed to market her remaining work capacity, so she was not entitled
to compensation.
-4-
ordinary disease[s] of life . . . arising out of and in the course of her employ[ment].” Second,

that the Commission erred by finding that Santora’s PTSD and major depressive disorder “arose

from her care of COVID patients in the course of her employment as a nurse.” Although framed

as separate assignments of error, both assert the same core argument: the Commission erred by

finding that Santora’s PTSD and major depressive disorder, and her resulting disability, are

compensable under the Virginia Workers’ Compensation Act.

“An ordinary disease of life” is compensable if, as relevant here, two elements are

“established by clear and convincing evidence.” Code § 65.2-401. First, that “the disease exists

and arose out of and in the course of employment . . . and did not result from causes outside of

the employment.” Code § 65.2-401(1). Second, that the disease “is characteristic of the

employment and was caused by conditions peculiar 6 to such employment.” Code

§ 65.2-401(2)(c). “The [C]ommission’s determination regarding causation is a finding of fact.”

City of Newport News v. Kahikina, 71 Va. App. 536, 545 (2020) (alteration in original) (quoting

Farmington Country Club, Inc. v. Marshall, 47 Va. App. 15, 26 (2005)). The Commission’s

decisions are “conclusive and binding as to all questions of fact.” Code § 65.2-706(A).

Inova asserts that evidence established that Santora’s PTSD and major depressive

disorder arose from “stressful events outside the workplace.” 7 We acknowledge that there is

evidence tending to show that Santora suffered from certain conditions before 2020. However,

this Court does “not retry the facts before the Commission nor do we review the weight,

preponderance of the evidence, or the credibility of witnesses.” Jeffreys v. Uninsured Emp.’s

6
Or, as the Commission put it: “the claimant’s PTSD and depression arose from her
care . . . in the course of her employment as a nurse.”
7
Inova also argues that Santora “had to prove by clear and convincing evidence that there
was actual exposure to a COVID patient on October 11, 2020 or October 21, 2020.” Inova does
not support this assertion with any legal authority.
-5-
Fund, 297 Va. 82, 87 (2019) (quoting Caskey v. Dan River Mills, Inc., 225 Va. 405, 411 (1983)).

“Instead, ‘we are bound by the [C]ommission’s findings of fact as long as “there was credible

evidence presented such that a reasonable mind could conclude that the fact in issue was

proved,” even if there is evidence in the record that would support a contrary finding.’”

Springfield Pest v. Peterman, 82 Va. App. 668, 679 (2024) (alteration in original) (emphasis

omitted) (quoting Artis v. Ottenberg’s Bakers, Inc., 45 Va. App. 72, 83-84 (2005) (en banc)).

The record supports the Commission’s finding that Santora’s PTSD and major depressive

disorder were compensable ordinary diseases of life caused by her employment. Santora testified

that caring for COVID-19 patients caused her PTSD and major depressive disorder because she

witnessed an immense amount of death in a short period of time and had no experience treating

people with respiratory conditions. “Causation of a medical condition may be proved by either

direct or circumstantial evidence, including medical evidence or ‘the testimony of a claimant.’”

Farmington Country Club, Inc., 47 Va. App. at 26 (emphasis added) (quoting Dollar Gen. Store

v. Cridlin, 22 Va. App. 171, 176 (1996)).

Additionally, Santora’s treatment providers corroborated her testimony. Per Olliver’s

records, Santora reported that her lack of preparedness and high degree of exposure “to severely

ill patients and death” negatively impacted her mental health. Similarly, Deloatch causally

related Santora’s acute mental distress and PTSD to her employment. Therefore, “there was

credible evidence presented” to support the Commission’s conclusion that Santora’s employment

caused her mental health symptoms. Artis, 45 Va. App. at 83 -84 (quoting Westmoreland Coal

Co. v. Campbell, 7 Va. App. 217, 222 (1988)).

The Commission found that Santora established a compensable disease by “clear and

convincing evidence.” Given the credible evidence presented, this finding was well within the

Commission’s discretion. The record supports the Commission’s conclusion that Santora’s PTSD

-6-
and major depressive disorder are compensable ordinary diseases of life arising out of and in the

course of her work as a nurse caring for COVID-19 patients.

CONCLUSION

Accordingly, this Court affirms the Workers’ Compensation Commission’s judgment.

Affirmed.

-7-

Source

Analysis generated by AI. Source diff and links are from the original.

Classification

Agency
VA Courts
Filed
March 24th, 2026
Instrument
Enforcement
Legal weight
Binding
Stage
Final
Change scope
Minor
Document ID
Record No. 1837-24-2
Docket
1837242

Who this affects

Applies to
Healthcare providers Employers
Industry sector
6211 Healthcare Providers
Activity scope
Workers' Compensation Claims
Geographic scope
Virginia US-VA

Taxonomy

Primary area
Employment & Labor
Operational domain
Legal
Topics
Healthcare Workers' Compensation

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