What is the current state of the law on employment causation for mental health injuries?

In Deziel, the Michigan court adopted a "strictly subjective causal nexus' standard" under which "a claimant is entitled to compensation [for mental injuries] if it is factually established that claimant honestly perceives some personal injury incurred during the ordinary work of his employment 'caused' his disability.... [p] The focal point of this standard is the plaintiff's own perception of reality." (Id., 268 N.W.2d at p. 11.) The board's limiting language in this case, that the claimed causal relationship between employment and injury not be a mere "after-the-fact rationalization," is equivalent to Michigan's "honest perception" rule. Its reservation of the question whether a psychiatric injury is compensable where the "employment was a mere passive element that a nonindustrial condition happened to have focused on" is a point of departure from the Deziel rule, which found industrial causation for a psychiatric disability where the applicant's job merely "perform[ed] the function of a convenient hook on which he can attach causation for troubles of all kinds and once this is set up, this traumatic event becomes the assigned cause by the patient." (Deziel v. Difco, supra, 268 N.W.2d at p. 18.)