What Do You Think?
Can the cumulative stress of long hours and frequent work travel turn a worker’s fatal cardiac event into a compensable workers’ compensation claim? What if the worker already had significant heart disease? A recent Connecticut case addressed whether the widow of a nuclear submarine manufacturer employee who regularly travelled and worked long hours could secure survivor’s benefits.
Going to Florida, especially when you’re used to cold Connecticut winters, should be relaxing, right?. According to the employee’s widow, her husband’s work trips to Florida were quite taxing. He began traveling to Cape Canaveral for work in 2019. He usually spent about two weeks in Florida, where he worked six days per week. After a two-week period, he would be at home for one week.
The worker had a history of cardiac issues and progressive heart disease. His treating doctors’ medical records didn’t mention work-related stress as a cause of those issues.
The widow claimed that the long hours and frequent travel caused cumulative physical and emotional stress that contributed to his fatal cardiac event in February 2020.
An administrative law judge denied the widow’s claim for benefits. The ALJ credited defense medical experts who attributed the worker’s death to his underlying progressive heart disease. Further, the evidence indicated that the worker “did not have high demand physical responsibilities while working at the Florida project,” the ALJ said.
Under Connecticut workers’ compensation law, a repetitive trauma injury must be causally connected to the worker’s employment. A claimant alleging that cumulative work stress contributed to an injury does not have to establish a sudden or unusual work stressor. However, the claimant still must prove the required causal connection between the employment and injury.
Did the widow establish a compensable claim?
A. Yes. Because this was a repetitive trauma claim, evidence that the worker’s extensive travel and long hours caused cumulative stress was enough to establish compensability even without a sudden or unusual work stressor.
B. No. She failed to show that work-induced stress was a substantial factor in her husband’s heart disease and death.
If you selected B, you agreed with the court in Zito-Hannan v. Electric Boat Corporation, No. AC 48801 (Conn. App. 09/01/26), which affirmed the dismissal of the widow’s claim for survivor’s benefits.
It was true that the widow did not have to show there was a sudden or unusual stressor to establish a repetitive trauma claim. However, she still had to prove that cumulative work stress substantially contributed to her husband’s death. Here, the evidence on that score was insufficient.
First, the cardiologists and primary care physician who treated her husband did not document work stress as a factor that contributed to his cardiac condition. Second, evidence showed that the worker did not perform highly demanding physical work on the Florida project. Third, medical opinions indicated that the worker’s underlying progressive heart disease, rather than psychological or physical work stress, caused his death.
Because the widow failed to connect the worker’s job stress to his death, the court dismissed her case.
