Background
Joseph Durden, a St. Johns County firefighter and paramedic since 2007, experienced heart palpitations and a rapid, irregular pulse while on vacation in August 2023. A hospital diagnosed him with atrial fibrillation, or AFib, and treated him with medication.
Durden sought workers’ compensation benefits for AFib and hypertension, including temporary disability, cardiology treatment, and payment of emergency care. The employer/carrier conceded that his preemployment physical showed no AFib and withdrew its causation rebuttal, but argued AFib was not “heart disease” under Florida Statutes section 112.18. The judge of compensation claims agreed and denied AFib compensability and related benefits, relying on North Collier Fire Control and Rescue District v. Harlem.
The Court’s Holding
The First District set aside the denial of compensability for Durden’s AFib and related benefits to the extent based on that ruling, and remanded for resolution of the remaining AFib-benefit issues. It held that AFib is “heart disease” under section 112.18’s presumption for firefighters.
The court concluded that the original meaning of “heart disease” when the Legislature enacted the statute in 1965 included functional conditions affecting the heart, not just structural or vascular conditions. Both medical experts described AFib as a disorder of the heart’s electrical system that disrupts normal cardiac function. Harlem’s discussion of vascular and valvular degradation was limited to the thoracic-aortic-aneurysm question presented there and did not exclude electrical arrhythmias such as AFib. The separate hypertension ruling remained undisturbed because Durden did not challenge it.
Key Takeaways
- AFib qualifies as heart disease for purposes of Florida’s firefighter heart-lung presumption.
- The statutory term includes functional electrical disorders of the heart, even without structural damage or vessel or valve degradation.
- Harlem’s definition addressed the cardiovascular condition in that case and is not an exhaustive definition for all section 112.18 claims.
Why It Matters
The decision confirms that firefighter claimants can invoke section 112.18 for qualifying cardiac arrhythmias, including AFib, when the statute’s other requirements are met. It also cautions against extending case-specific language about heart disease beyond the medical condition and legal question actually decided.