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1st DCASeptember 23, 2026Affirmed⭐ Notable

Village Center Community Development District v. Illeck

Case No. 1D2025-3075

A firefighter developed supraventricular tachycardia and atrial tachycardia and obtained workers' compensation benefits under the heart-lung statute's presumption of compensability, y112.18(1), Fla. Stat. The employer-carrier argued that North Collier Fire Control & Rescue District v. Harlem narrowly defined 'heart disease' to exclude arrhythmias. The First DCA affirmed, holding Harlem's definition was limited to cardiac 'plumbing' conditions (arteries, valves, blood pressure) and does not foreclose coverage for electrical-system heart disease.

Key facts

  • A firefighter developed supraventricular tachycardia and atrial tachycardia and sought workers' compensation benefits under the heart-lung statute's presumption of compensability.
  • The employer-carrier argued that a prior case narrowly defined 'heart disease' to exclude arrhythmias, but unrebutted medical testimony from cardiologists established the conditions as heart disease.
  • +2 more key facts with a free trial

Why it matters

This decision materially cabins Harlem, which employer-carriers had been using to argue for a narrow definition of 'heart disease' that would defeat the section 112.18 presumption. Claimants' counsel in first-responder… — full analysis with a trial

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