Case File
A Florida appellate court ruled that atrial fibrillation qualifies as “heart disease” under Florida’s firefighter heart-lung presumption statute, allowing a firefighter to invoke the presumption even though the condition did not involve vascular or valvular degradation described in prior case law.
Case
Durden v. St. Johns County, No. 1D2024-1623 (Fla. Dist. Ct. App. 11/04/26)
What Happened?
While on vacation, a Florida firefighter awoke with heart palpitations and a rapid, irregular pulse. He went to the hospital, where he was diagnosed with AFib and treated with medication.
The firefighter later sought workers’ compensation benefits for AFib and hypertension. He requested temporary disability benefits, cardiology treatment, and payment for emergency hospital care, and related relief.
At the final hearing, the employer/carrier acknowledged that the firefighter’s pre-employment physical revealed no evidence of AFib and conceded that he satisfied the statute’s disability requirement if AFib qualified as heart disease. The E/C also withdrew its defense seeking to rebut the statutory presumption of occupational causation.
Two independent medical examiners testified that AFib is heart disease; they described it as an electrical disorder that disrupts the heart’s normal function.
The Judge of Compensation Claims acknowledged the examiners’ testimony but read North Collier Fire Control and Rescue District v. Harlem, 371 So. 3d 368 (Fla. Dist. Ct. App. 2023) to limit “heart disease” to conditions that weaken the heart through degradation of vessels or valves. Because the firefighter’s AFib didn’t meet that reading of Harlem, the JCC denied compensability and the related claims for benefits.
The firefighter appealed to the Florida’s Distict Court of Appeals, raising the question of whether atrial fibrillation qualified as “heart disease” within the meaning of the heart-lung statute.
Rule of Law
Florida law gives firefighters a rebuttable presumption that a disabling condition caused by tuberculosis, heart disease, or hypertension arose from their work. To qualify, a firefighter must also have passed a physical examination upon entering service that revealed no evidence of the claimed condition. Once these requirements are met, the presumption supplies the link between the condition and the firefighter’s work.
What the Court Said
In the court’s view, the firefighter’s AFib fell within the meaning of “heart disease,” under the statute, even if it didn’t involve degradation of the heart muscle. The court concluded that Harlem did not establish an exclusive definition of heart disease limited to conditions involving deterioration of the heart’s vessels or valves. Instead, prior cases recognized heart disease more broadly to include functional abnormalities affecting the heart itself.
The court explained that because the legislature didn’t define “heart disease” in the statute, its job was to consider what the term meant at the time the statute was enacted in the late 1950s.
“The testimony here is consistent with … historical understanding,” the court wrote. “Both cardiologists identified AFib as heart disease and confirmed that it was recognized as such in the 1950s and 1960s.”
The court rejected the E/C’s interpretation of Harlem, which described “heart disease” as a disease affecting and weakening the heart muscle through “degradation of the vessels or valves.” Instead, the court distinguished Harlem, which involved a thoracic aortic aneurysm and itself relied on City of Venice v. Van Dyke, 46 So. 3d 115 (Fla. Dist. Ct. App. 2010). The Van Dyke court considered “heart disease” to be “any organic, mechanical, or functional abnormality of the heart, its structures, or the coronary arteries.”
The court found that unlike the aneurysm in Harlem, the firefighter’s AFib affected the heart itself by disrupting the electrical activity that controls normal atrial contractions.
“It is a functional disorder of the kind recognized as heart disease when [the statute] was enacted,” the court wrote.
Verdict: The court set aside and remanded the JCC’s ruling.
Takeaway
Under Florida’s heart-lung presumption, AFib disrupts the heart’s electrical function despite not involving vascular or valvular degradation described in precedent case law, since that definition did not foreclose coverage of disorders involving the heart’s electrical system and Florida courts have long treated cardiac arrhythmias as heart disease.
