Benefits blocked due to failure to show plaque rupture occurred at work
Case name: Henry v. Department of Correction, No. 39039-2011, 2013 Opinion No. 9 (Idaho 01/23/13).
Ruling: The Idaho Supreme Court held that a prison guard was not entitled to benefits for the heart attack he suffered while at work.
What it means: In Idaho, a worker will not be entitled to benefits for a heart attack if his doctor cannot determine whether the heart attack was triggered by events occurring before or after he arrived at work.
Summary: A prison guard suffered a heart attack shortly after arriving at work. The weather was below freezing, and he arrived to work late, so he was walking quickly. A cardiologist determined that he suffered a blockage in an artery. Later, he suffered another cardiac event while undergoing a cardiac stress test. The next day, he underwent triple bypass surgery. He sought workers' compensation benefits, contending that the surgery was related to his heart attack at work and that the heart attack exacerbated his preexisting anxiety, rendering him totally and permanently disabled. The Idaho Supreme Court held that he was not entitled to benefits.
The guard was 54 years old, suffered from chronic anxiety, had hypertension, sleep apnea, hypercholesterol, and smoked cigarettes for 38 years. The court pointed out that his preexisting condition was not a bar to receiving benefits.
The court found that the guard failed to establish that his heart attack was triggered by his activities at work. The cardiologist stated that the cold temperature, time of day, the guard's activity level, and his mental stress contributed to his heart attack.
The court explained that the cardiologist could not state that the plaque rupture that ultimately caused the blockage occurred at work. The cardiologist did not testify as to how long after the plaque rupture it took for the blood clot to form to the extent that it blocked the artery. Also, the cardiologist did not exclude the events that occurred before the guard's arrival at work as a possible cause of his heart attack.
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April 18, 2013
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