Can an employer be held liable for emotional distress under the California Workers' Compensation Act?

Cole v. Fair Oaks Fire Protection Dist., supra, 43 Cal.3d 148, 160, 233 Cal.Rptr. 308, 729 P.2d 743, points out "disabilities caused by stresses in the workplace are compensable [under the Workers' Compensation Act] whether or not the employer was at fault." Cole dealt with a physical disability case rather than a pure emotional distress situation and involved a case that arose before the exclusive remedy statutes were changed effective January 1, 1983 (Stats.1982, ch. 922, supra ). Yet, I believe its test for application of the exclusive remedy rule, that is, whether the acts complained of were "a normal part of the [194 Cal.App.3d 241] employment

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