Is a Heart Attack Compensable?

When a worker suffers a heart attack while inspecting motors at a factory, he applies for workers' comp.

By Christina Lumbreras

A team leader for a motor manufacturing company performed spot checks of parts for 10 hours each day. He would pick up a 15-pound part off the line and bring it to a table where he would measure it and turn it several times to perform a qualify check. He also performed checks that required him to place 75 to 100 parts on a cart and transport them to a lab.

Shortly after lunch, he gradually began "feeling bad." The leader said that he had arm pain and was nauseated and sweating. He continued to do his checks. Later, his supervisor sent him to sort defective parts with two other employees. The leader said that the job was so overwhelming that the supervisor had to call in 10 other employees to help with the task. Eventually, the leader told the supervisor that he wasn't feeling well and that he had to see a doctor.

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The company's safety manager drove him to the hospital. An EKG indicated that he was having a severe heart attack. He underwent urgent cardiac catheterization and stent implantation. A surgeon noted a history of hypertension. He was diagnosed with severe coronary artery disease. He underwent a coronary artery bypass graft.

A doctor explained that the leader's heart attack was the result of an acute plaque rupture. He stated that the leader's heart had a number of blockages and the total blockage of the leader's coronary artery may have occurred abruptly, even as early as the afternoon of the heart attack. The doctor explained that no one knows the cause of the type of catastrophic plaque rupture that the leader suffered. Also, no one knows what causes the rupture to occur at the time and place that it does.

The leader sought workers' compensation benefits. The administrative law judge found that the leader did not suffer a compensable heart attack. The Arkansas Workers' Compensation Commission affirmed the ALJ's decision. The leader appealed.

Was the commission correct in finding the heart attack was not compensable?

A. No. The leader started exhibiting symptoms of his heart attack at work.

B. Yes. The doctor could not provide a medical opinion as to what caused the leader's plaque rupture.

C. No. The leader's additional task of sorting through defective parts was the major cause of his heart attack.

How the court ruled: B. The Arkansas Court of Appeals held that the worker's heart attack that occurred at work was not compensable. Kimble v. Hino Motors Manufacturing USA, Inc., No. CA11-859 (Ark. Ct. App. 11/07/12).

The court pointed out that no one in the medical community knew what caused the type of plaque rupture that the leader suffered.

A is incorrect. The court explained that although the leader's symptoms began while he was at work, he was performing his regular job duties. He was not doing work that required him to exert himself in a manner that was extraordinary or unusual in comparison to his usual work.

C is incorrect. The court said that the leader did not have a medical opinion stating that his task of sorting through defective parts was the major cause of his heart attack.

Editor's note: This feature is not intended as instructional material or to replace legal advice.

Read more at the WorkersComp Forum homepage.

February 12, 2013

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