Two cardiologists said heart disease. The comp judge went to the dictionary instead
A Florida firefighter woke up on vacation with a racing heart - and what followed just reshaped the state’s workers’ comp law.
The firefighter had served with St. Johns County Fire Rescue since 2007. On August 24, 2023, while on holiday, he woke to heart palpitations and a rapid, irregular pulse. He was diagnosed with atrial fibrillation - AFib, where the heart’s electrical signals misfire - treated, and discharged the same day.
He filed for workers’ compensation under Florida’s heart-lung statute, section 112.18, which gives firefighters a rebuttable presumption - the employer bears the burden of proving otherwise - that heart disease arose from their work, provided they showed a clean bill of health on entry.
The employer and its carrier, Preferred Governmental Claims Solutions, barely pushed back. They acknowledged his pre-employment physical was clear. They conceded the disability requirement. They even withdrew their challenge to the occupational link.
That left one question. Was AFib “heart disease”?
Both independent cardiologists said yes. Both described it as an electrical disorder disrupting the heart’s normal function. Neither found structural damage, weakened vessels, or degraded valves.
The compensation judge saw it differently. Relying on a 2023 appellate decision, North Collier Fire Control and Rescue District v. Harlem, the judge read “heart disease” as limited to conditions that physically weaken the heart - damaged valves, clogged vessels. AFib didn’t fit. Claim denied.
Florida’s First District Court of Appeal set that ruling aside on November 4, 2026.
The court went back to 1965, when the legislature wrote the statute without defining “heart disease.” A 1957 medical dictionary defined it as “any organic, mechanical, or functional condition of the heart that causes trouble.” The World Health Organization classified auricular fibrillation under functional heart disease that same year. The term had always covered conditions disrupting how the heart works - not just those damaging its structure.
The court found Harlem had been stretched too far. That case involved an aneurysm in the thoracic aorta - a bulge in a large artery leading from the heart. Different organ, different question. A September 2026 decision in Illeck confirmed the point: Harlem’s was a “limited-purpose definition” never meant to shut the door on electrical heart conditions.
With every other requirement uncontested, the court held the firefighter’s AFib was covered. The case goes back for remaining benefit issues. A separate denial involving hypertension, which he did not challenge, stays in place.
For HR teams handling first-responder comp in Florida, the takeaway is direct: functional heart conditions like AFib sit within the heart-lung presumption.
The decision is not yet final pending any timely motions under Florida’s appellate rules.
