Case name: Davis v. Ryan, No. 11AP-198 (Ohio Ct. App. 01/31/12).
Ruling: The Ohio Court of Appeals held that a worker's heirs were not entitled to death benefits for her death due to an acute myocardial infarction.
What it means: In Ohio, a doctor's inability to pinpoint a cause of death with a reasonable degree of medical certainty will impede a claim for death benefits.
Summary: A clerical worker for a state educational association had a preexisting cardiac condition and had undergone double coronary bypass surgery. After the surgery, she returned to work and was not placed on any long-term exercise or walking restrictions. One year after her surgery, she apparently suffered a myocardial infarction after walking in a parking lot at work. Her usual accessible parking spot was blocked by a truck, so she had to park in a lot one block away. The administrator of her estate sought death benefits. The association asserted that there was no causal connection between the worker's employment and her death. The Ohio Court of Appeals denied the claim for death benefits.
The worker's cardiologist said she was morbidly obese, she smoked two packs of cigarettes per day, and suffered from numerous health problems. The cardiologist said he could not conclude, within a degree of medical probability, that the act of walking would trigger an acute myocardial infarction.
The administrator of the estate also argued that the worker's attempt to walk to the building aggravated her preexisting condition. The court disagreed, pointing out that the cause of her death was unknown and that the theory was speculative and unsupported by evidence.
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April 2, 2012
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