Background
William K. Willis, a deputy sheriff, suffered a heart attack on October 29, 2023, while apprehending a criminal. Willis claimed the heart attack resulted from the heightened stress and job duties he performed during the arrest. Although Willis had a prior history of chest pain caused by Barrett’s Esophagus (severe acid reflux), he argued he could distinguish that pain from the cardiac event at issue. The employer denied the workers’ compensation claim, contending that Willis failed to provide medical evidence of a causal connection between his work duties and the heart attack.
The claim was initially rejected by the claim administrator on December 7, 2023. The Workers’ Compensation Board of Review affirmed the rejection on October 8, 2024, finding Willis relied on speculation rather than medical evidence. The Intermediate Court of Appeals affirmed on August 29, 2025, and Willis appealed to the Supreme Court of Appeals.
The Court’s Holding
The Supreme Court of Appeals unanimously affirmed the rejection of Willis’s workers’ compensation claim. The court held that Willis failed to present medical evidence establishing that his heart attack was caused by his work activities. Speculation about causation is insufficient to sustain a workers’ compensation claim under West Virginia law.
The court emphasized that a heart attack suffered at work is not automatically compensable; the claimant must establish a causal connection between job duties and the cardiac event. Medical records demonstrated Willis had pre-existing heart disease, as evidenced by his treatment with ACE inhibitors and beta blockers from May 2017 through August 2023. Without medical proof linking the heart attack to workplace activities, Willis’s arguments based on work stress did not meet the burden of proof.
The court reviewed questions of law de novo but accorded deference to the Board of Review’s factual findings, finding none clearly erroneous. The decision was issued as a memorandum opinion.
Key Takeaways
- Cardiac events at work require medical evidence—not speculation—to establish compensability under West Virginia workers’ compensation law
- Pre-existing heart disease or cardiac risk factors do not bar recovery but require clear differentiation and causal proof
- Heightened workplace stress or dangerous working conditions alone, without medical corroboration, are insufficient to prove a work-related heart attack
Why It Matters
This decision sets a high evidentiary bar for law enforcement and other high-stress occupations seeking workers’ compensation for cardiac events. Although deputies face genuine occupational hazards, courts will not presume causation without medical evidence specifically linking the heart attack to job performance. The ruling protects employers from speculative claims while ensuring claimants with genuine work-related cardiac injuries can still obtain relief if they present proper medical documentation.
For workers’ compensation practitioners, the decision underscores the importance of obtaining detailed medical evidence—including expert testimony on causation—in cardiac injury cases. The court’s deference to Board of Review factual findings means appellate relief will be rare absent clear error. Claimants must build medical evidence contemporaneously with the injury to succeed on appeal.