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Retired firefighter’s heart disease compensable

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A retired firefighter is entitled to workers compensation for his heart disease, the Supreme Court of Connecticut held Tuesday.

In Coughlin v. Stamford Fire Department, the state’s high court unanimously affirmed a Connecticut Compensation Review Board decision granting benefits to a firefighter who filed a claim for hypertension while employed that he said led to his later diagnosis of heart disease.

Firefighter John Coughlin filed a claim for workers compensation for heart disease, although at the time of his diagnosis and disability, he had already retired from his position as a firefighter. He began working for the fire department in 1975 and filed a claim for hypertension benefits in 2011. He retired two years later, and in 2016, he was awarded compensation for his hypertension. A report from his physician stated that his hypertension was a significant factor in his development of coronary artery disease. He later pursued a claim for heart disease on the basis that it flowed from his hypertension claim.

The Stamford Fire Department, where Mr. Coughlin had been employed, denied the claim on the basis that he was no longer employed at the time he made his claim and that he failed to establish an injury of heart disease on the basis of a causal relationship to an initial compensable claim for hypertension because they are two separate and distinct injuries. 

A workers compensation commissioner denied Mr. Coughlin’s request for benefits on the basis that he was retired when he was diagnosed with coronary artery disease. However, the Connecticut Compensation Review Board reversed the decision. Stamford appealed.

The Connecticut Supreme Court affirmed the decision of the board, holding that nothing in the plain reading of the state’s statutes require that hypertension and heart disease be treated as separate diseases if they are causally related.

The court note that under the state’s Workers Compensation Act, an employee, “having suffered a compensable primary injury during the course of his employment, may also be compensated for a subsequent injury that occurs outside the course of employment” so long as it is “the direct and natural result of a compensable primary injury.”

The court found that it was undisputed that Mr. Coughlin’s initial claim for hypertension was timely and compensable, and that he may submit claims for subsequent injuries that flow from his primary claim under the Act. In addition, the court noted that Mr. Coughlin presented evidence from his physician that his hypertension was “a significant factor in the development of his heart disease,” and affirmed the board’s conclusion that Mr. Coughlin is entitled to compensation for his heart disease.

 

 

 

 

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