Case name: City of Beaumont v. O'Quinn, No. 09-09-00448-CV (Tex. Ct. App. 09/16/10).
The Texas Court of Appeals held that a firefighter was not entitled to compensation for his coronary artery disease, high-density lipoprotein, and gastritis.
it means: To be entitled to benefits for a condition diagnosed after a compensable injury, a worker must show that the condition was caused or aggravated by the compensable injury.
Summary: A firefighter suffered a heart attack while working for a city. The city paid medical benefits for approximately two to three years and then workers' compensation denied coverage of his medications. Coverage was switched to his medical insurance provider. Later, the firefighter was diagnosed with coronary artery disease, high-density lipoprotein, and gastritis. He sought compensation for these conditions. The Texas Court of Appeals held that the conditions were not compensable.
The court noted that the firefighter had multiple risk factors for developing coronary artery disease, such as heavy smoking and a family history. A doctor testified that certain medications were prescribed to the worker as a result of the heart attack and the damage to his heart. The firefighter was not diagnosed with coronary artery disease or gastritis until after the heart attack. However, the doctor did not provide evidence that either the coronary artery disease or gastritis was caused by or aggravated by the heart attack. In fact, the doctor testified that the conditions were not related to the heart attack.
The firefighter also presented a letter in which his doctor stated that his disability was "a direct result of the work-related injury." The court stated that the opinions were "bare conclusions" insufficient to support a finding of compensability.
The court stated that the firefighter suffered from peptic ulcer disease at the time of his heart attack and medications exacerbated the condition. Additionally, the gastritis was drug-induced and not a result of the work-related heart attack.
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November 22, 2010
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