The officer was 80 and hadn't worked in 16 years – here's what the court decided
A Connecticut court has ruled that a retired police officer's disability benefits cannot be set at zero – no matter how long ago he stopped working.
In a decision, the Connecticut Appellate Court affirmed a workers' compensation award that carries a clear message for employers: your workers' compensation obligations do not expire when an employee walks out the door for the last time.
Louis Martinoli spent more than two decades with the Stamford Police Department before retiring in October 1999 at age 64. Earlier that year, he had established a compensable claim for coronary artery disease, hypertension, and congestive heart failure under a Connecticut statute that covers police officers and firefighters who develop heart conditions after passing a clean physical upon entering service. He underwent quadruple bypass surgery, received a permanent partial disability rating of 43.75 percent to the heart, and collected weekly benefits. He never returned to work and never intended to.
Then, 16 years later, his health took another turn.
On July 15, 2015, at 80 years old, Martinoli was admitted to the hospital with abdominal pain, developed atrial fibrillation, and sustained a stroke. A workers' compensation commissioner found those conditions flowed directly from his original heart disease claim, making them compensable. Both sides agreed he had been temporarily totally disabled since that date.
The fight was over money – specifically, how much.
The Stamford Police Department and its workers' compensation insurer, PMA Management Corp. of New England, argued that Martinoli's benefit rate should be based on his earnings during the 52 weeks before he became disabled. Since he had been retired for 16 years with no income, they said, the rate should be zero.
The court was not persuaded. It found that allowing a zero-dollar rate would effectively gut the right to benefits that the Connecticut Supreme Court had already confirmed in a 2024 ruling, which established that workers who become totally incapacitated after voluntary retirement remain eligible for disability benefits.
Instead, the court turned to Connecticut's wage calculation statute, which provides that when an employee has not been working in the period immediately before the onset of disability, benefits must be based on the prevailing wages for the same or similar employment in the same area. For Martinoli, that meant the going rate for Stamford police officers at the time he became disabled in 2015 – not his 1999 earnings, and certainly not zero.
The defendants also sought a credit against a permanent partial impairment award for disability payments made after Martinoli reached maximum medical improvement in May 2016. The court declined to take up that question, finding it premature. The commissioner had already scheduled further hearings on credits, and the court noted significant gaps in the record, including uncertainty about what payments had actually been made. Martinoli died during the pendency of the appeal before the Connecticut Supreme Court, and Dawn Re, the administrator of his estate, was substituted as the plaintiff.
For HR professionals – particularly those managing public-sector workforces – the takeaway is straightforward. Workers' compensation claims can resurface years or even decades after an employee retires, and the benefits owed will not be pegged to some distant historical wage. They will reflect what the job pays now. That is a long-tail liability worth tracking, especially for municipalities and agencies employing police officers, firefighters, and other workers covered by heart and hypertension presumption laws that exist in numerous states across the country.
Retirement, the court made clear, closes a career. It does not close a claim.
