In the case of United States v. Lorenzetti in 1983, the U.S Supreme Court ruled that federal employees who are injured on duty and receive compensation from their employer cannot also claim damages for emotional distress caused by the physical injury. The court held that under the Federal Employees' Compensation Act (FECA), an employee's recovery is limited to workers' compensation benefits provided by FECA, which does not include damages for pain and suffering or emotional distress. This ruling came after Robert Lorenzetti, a federal employee who was injured at work due to negligence of his co-workers, sought additional compensation beyond what he received through FECA for his physical injuries. He argued that he suffered from severe depression as a result of his injuries but this argument was rejected by the court.

In the dissenting opinion for United States v. Lorenzetti, Justice Stevens argued that the majority's decision to limit recovery of damages in Federal Tort Claims Act (FTCA) cases was inconsistent with Congress' intent when enacting the law. He contended that there is no language in FTCA suggesting a limitation on compensatory damages and therefore, it should be interpreted as allowing full compensation for all proven injuries. Furthermore, he criticized the majority’s reliance on state laws to justify their position because FTCA does not require conformity with state laws regarding damage awards. Lastly, he disagreed with limiting emotional distress claims only to instances where physical injury occurred first; this approach failed to recognize severe mental suffering can occur without preceding physical harm.