Background
Chelsea Illeck became a full-time firefighter for the Villages Community Development Districts in 2014 after a pre-employment physical showed no evidence of heart disease. In fall 2023, she experienced chest pain, shortness of breath, and a racing heart while transporting a patient. She was diagnosed with supraventricular tachycardia (SVT), an abnormal rhythm originating in the heart’s upper chambers.
After her symptoms persisted, Illeck underwent a cardiac ablation in March 2024, missed work, and later moved to light-duty and quality-assurance roles. She reported her injury in April 2025 and sought workers’ compensation benefits under Florida’s heart-lung statute, section 112.18(1). After the employer and carrier denied the claim, she underwent a second ablation in August 2025 for continuing symptoms and arrhythmias.
Both parties’ cardiologists diagnosed Illeck with SVT and atrial tachycardia and testified that these electrical-system rhythm disorders constituted heart disease, although they did not fit the definition applied in North Collier Fire Control & Rescue District v. Harlem. The Judge of Compensation Claims credited that testimony, applied the statutory presumption of compensability, and awarded benefits.
The Court’s Holding
The First District affirmed. It held that Harlem did not prevent an arrhythmia-based condition involving the heart’s electrical system from qualifying as “heart disease” under section 112.18(1). Harlem addressed a thoracic aortic aneurysm and used a limited definition suited to cardiac “plumbing” conditions involving arteries, valves, and blood pressure; it did not purport to exclude electrical disorders arising within the heart.
The only competent medical evidence established that Illeck’s SVT and atrial tachycardia were heart diseases and had been medically understood as such since the statute’s 1965 enactment. The court also noted its longstanding precedent treating arrhythmias, atrial fibrillation, and tachycardia as heart disease under the statute. Because the employer and carrier offered no contrary medical evidence, the court found no basis to disturb the compensation order.
Key Takeaways
- Florida’s heart-lung statute can cover heart disease involving the heart’s electrical system, including SVT and atrial tachycardia.
- Harlem’s definition of heart disease was limited to the cardiac and vascular condition presented there and did not categorically exclude arrhythmia-based disorders.
- Unrebutted medical testimony that the claimant’s rhythm disorders constituted heart disease supported application of the statutory presumption and the benefits award.
Why It Matters
The decision limits Harlem to its factual and medical context and confirms that its “plumbing”-focused discussion did not narrow section 112.18 to coronary, blood-pressure, or valve disorders. Firefighters with disabling electrical-system heart conditions may still invoke the statutory presumption when competent medical evidence establishes that their conditions are heart disease.
The opinion also underscores the importance of the evidentiary record in workers’ compensation proceedings: although Illeck cited historical medical publications on appeal, the court relied on the unrebutted testimony presented to the Judge of Compensation Claims rather than materials outside the hearing record.