MICHAEL LEBLANC, APPELLANT,
v.
CITY OF WEST PALM BEACH AND JOHNS EASTERN COMPANY, APPELLEES
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A firefighter appealed a workers' compensation decision denying benefits for cardiac arrhythmia. The court reversed, holding that the employer failed to rebut the statutory presumption of work-relatedness by merely establishing that the physiological cause was unknown, rather than proving a specific non-occupational cause.
No. The court held that to rebut the presumption of work-relatedness, the employer must affirmatively demonstrate a specific non-occupational cause, not merely establish that the cause is unknown. Evidence that a condition results from a physiological defect without identifying the legal cause does not sufficiently rebut the presumption.
[1] A "non-occupational cause" sufficient to rebut the presumption of work-relatedness for a firefighter's cardiac arrhythmia must be affirmatively demonstrated, not merely e…
[2] Evidence that the physiological cause of a medical condition is unknown does not, without more, establish a non-industrial legal cause of that condition.
Previewing 2 of 4 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“A determination of the physiological cause of a disease or medical diagnosis — although perhaps helpful under some circumstances in determining the sufficient, or legal, cause of a medical condition — does not, without more, establish the legal cause of the condition, but rather, evades the issue altogether.”
The court's core holding that physiological causation is distinct from and insufficient to establish legal causation for purposes of rebutting the presumption.
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceClaimant, a firefighter, developed cardiac arrhythmia. The employer and its workers' compensation carrier presented medical evidence that the sufficie…
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In this workers’ compensation appeal, Claimant, a firefighter, challenges an order of the Judge of Compensation Claims (JCC) that finds that his Employer and its workers’ compensation carrier (the E/C) introduced sufficient evidence to establish a non-occupational cause of his cardiac arrhythmia. Claimant argues that testimony establishing that the cause of Claimant’s condition was unknown was insufficient to demonstrate that the condition, in fact, had a non-industrial cause. We agree and reverse.
Here, there is no dispute that Claimant established the legal conditions for the operation of the presumption found in section 112.18(1), rendering his cardiac arrhythmia work-related and, thus, compensable under the Workers’ Compensation Law — unless sufficiently rebutted by the introduction of evidence establishing a non-industrial cause. See Punsky v. Clay County Sheriffs Office, 18 So.3d 577, 583 (Fla. 1st DCA 2009). The medical evidence accepted as credible by the JCC established that the sufficient cause of Claimant’s condition was unknown; Claimant could have developed the condition notwithstanding his occupation; and, “mechanistically,” the condition is caused by an electrical defect in the cells of the heart. From this, the JCC concluded that the E/C sufficiently established a non-occupational cause of Claimant’s condition.
By finding that Claimant’s condition, which, by definition, is an electrical defect of the heart, was caused by a defect of the heart — the cause of which is unknown — the JCC devalued and eviscerated the legal presumption of com-pensability afforded by section 112.18(1). A determination of the physiological cause of a disease or medical diagnosis — although perhaps helpful under some circumstances in determining the sufficient, or legal, cause of a medical condition — does not, without more, establish the legal cause of the condition, but rather, evades the issue altogether.* Moreover, here, the medical testimony *183that the JCC accepted as credible established that the sufficient cause of Claimant’s condition was unknown, based on the evidence presented, — an empty set that precludes a contrary postulate. See generally Fuller v. Okaloosa Corr. Inst., 22 So.3d 803, 806 (Fla. 1st DCA 2009) (stating, to rebut 112.18 presumption, E/C required to affirmatively demonstrate non-work-related cause, not prove that there is no known cause). Accordingly, we REVERSE the denial of benefits and attorney’s fees and costs, and REMAND the case for the entry of an order awarding same.
BENTON, C.J., THOMAS and RAY, JJ., concur.
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City OF Jacksonville/City of Jacksonville Risk Mgmt. v. Ratliff, 217 So. 3d 183 (Fla. 1st DCA 2017)…the meeting could have been a possible cause. Because the E/C could not, by competent evidence, show that “the” or “all” possible factors causing the “trigger event” were non-work related, the presumption prevails. LeBlanc v. City of W. Palm Beach, 72 So. 3d 181 (Fla. 1st DCA 2011).12 This matter does not require remand to the JCC, as the Final Order documents the JCC’s findings with regard to the unknown causation of the “triggering” event. The JCC specifically found, “[Dr. Dietzius] agreed that the cause…
Authorities Cited
- Punsky v. Clay Cnty. Sheriff's Off. & Scibal Ins. Grp., 18 So. 3d 577 (Fla. 1st DCA 2009)
- Fuller v. Okaloosa Corr. Inst. & Div. of Risk Mgmt., 22 So. 3d 803 (Fla. 1st DCA 2009)