Wynn v. Navajo Freight Lines, Inc.

DONNELLY, Judge,

dissenting.

The principal opinion expands Wolfgeher to permit recovery for “heart attacks” occurring during the course of employment without regard to causation.

Arthur Larson has proposed a special test for heart cases. IB Larson, Workmen’s Compensation Law, § 38.83 (1982). It is intended to account for causation, a key problem in heart cases. The causation requirement can be broken down into two parts, the legal and the medical. To satisfy the legal causation requirement, exertion or strain (whether usual or unusual) must have arisen “out of the employment.” Larson’s test provides a way of determining this both for situations in which there was a previously weakened or diseased heart and for where there was no prior weakness or disease. To satisfy the medical causation requirement, doctors must say whether the exertion or strain found legally sufficient to support compensation in fact caused this collapse. Larson’s test is as follows:

If there is some personal causal contribution in the form of a previously weakened or diseased heart, the employment contribution must take the form of an exertion greater than that of nonemployment life. * * * Note that the comparison is not with this employee’s usual exertion in his employment but with the exertions of normal nonemployment life of this or any other person.
If there is no personal causal contribution, that is, if there is no prior weakness or disease, any exertion connected with the employment and causally connected with the collapse as a matter of medical fact is adequate to satisfy the legal test of causation. * * *.
In both situations, with or without pri- or personal weakness or disease, the claimant must also show that medically the particular exertion contributed causally to the heart attack.

Larson, § 38.83, p. 7-237.

Under the Larson test, merely having a heart attack on the job is insufficient to require compensation. This is because, as heart problems are understood, they can result either from external conditions or events (here relating t£> employment), or from the internal condition of the heart and body itself, or from a combination of the two. Under such a compensation test specific to heart conditions, only those heart attacks resulting solely or largely from employment are compensable.

I would apply the Larson test in this case. Here, the employee had pre-existing heart disease and there was no abnormal or unusual strain in connection with his employment. Under the Larson test, the requirement of legal causation is not satisfied.

I respectfully dissent.