Durden v. St. Johns County Fire Rescue/Preferred Governmental Claims Solutions
A firefighter diagnosed with atrial fibrillation was denied the section 112.18 heart-lung presumption because the JCC read North Collier Fire Control & Rescue District v. Harlem to limit 'heart disease' to conditions weakening the heart through degradation of vessels or valves. The First DCA held that the 1965 original meaning of 'heart disease' included functional disorders of the heart, that AFib is such a functional (electrical) disorder, and that Harlem supplied only a limited-purpose definition tied to a thoracic aortic aneurysm. The denial of AFib compensability was set aside and the case remanded.
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Key facts
- A firefighter employed by St. Johns County Fire Rescue was diagnosed with atrial fibrillation and filed a workers' compensation claim under the section 112.18 heart-lung presumption.
- The judge of compensation claims denied the claim, interpreting North Collier Fire Control & Rescue District v. Harlem to limit 'heart disease' to conditions involving degradation of vessels or valves, and concluded atrial fibrillation did not qualify.
- +2 more key facts with a free trial
Why it matters
This opinion materially narrows Harlem, which employers and carriers had been using to defeat heart-lung presumption claims involving arrhythmias and other non-structural cardiac conditions. Workers' compensation… — full analysis with a trial
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