Background
Shawna Zito-Hannan sought workers’ compensation survivor benefits after her husband, longtime Electric Boat employee Michael Joseph Hannan, died in his sleep from a cardiac event in February 2020. Hannan had preexisting heart disease and other cardiac risk factors. In the months before his death, he frequently traveled to Florida for work and worked six days per week while there.
Zito-Hannan alleged that the cumulative physical and emotional stress of Hannan’s work and travel substantially contributed to his fatal cardiac event. The administrative law judge dismissed the claim after crediting evidence that Hannan’s death resulted from his underlying progressive heart disease and that his work was not a substantial contributing factor. The Compensation Review Board affirmed.
The Court’s Holding
The Connecticut Appellate Court affirmed the board’s decision. Reading the administrative law judge’s decision as a whole, the court concluded that the judge understood and rejected Zito-Hannan’s repetitive-trauma theory rather than improperly requiring proof of a sudden or unusual workplace stressor.
The court held that the administrative law judge made sufficient findings on causation and was entitled to credit Electric Boat’s medical experts over conflicting evidence from Zito-Hannan’s expert. Evidence supporting the ruling included the absence of work-stress notations in Hannan’s treating physicians’ records, testimony about his work responsibilities, and expert opinions attributing his death to progressive heart disease rather than work-related stress.
Key Takeaways
- A repetitive-trauma claim does not require proof of a sudden or unusual workplace event, but the claimant must establish a causal connection between the employment and the injury.
- An administrative decision must be read as a whole; isolated references to the absence of a sudden stressor did not show that the wrong legal standard was applied.
- Appellate courts will not reweigh conflicting medical testimony when the administrative law judge’s causation finding is supported by evidence in the record.
Why It Matters
The decision underscores the evidentiary burden in workers’ compensation claims alleging that cumulative workplace stress aggravated a preexisting cardiac condition or caused death. Evidence that work was stressful, without persuasive proof that the stress substantially contributed to the claimed injury, may be insufficient.
It also confirms the substantial deference afforded to administrative law judges on witness credibility, expert testimony, and competing causation inferences.