The US Court of Appeals for the Eighth Circuit in Florida has ruled that the Judge of Compensation Claims (JCC) erred in entering a judgment in favor of a corrections officer for a cardiac injury because medical evidence showed that strenuous exercise triggered the degeneration of his congenital heart condition into atrial fibrillation. The case is City of Jacksonville v. O'Neal, No. 1D19-597, 2020 Fla. App. LEXIS 5471 (Dist. Ct. App. Apr. 23, 2020).

In 2002, Adrian O'Neal, the claimant, was a twenty-nine-year-old corrections officer who began experiencing heart problems. Reportedly, when exercising, O'Neal's heart would flutter, causing lightheadedness. At that time, he was training to participate in Olympic-type track and flag-football competitions. He sought medical advice for his heart issues, and was diagnosed with atrial tachycardia and atrial fibrillation. On June 26th of that year, O'Neal underwent a cardiac catheterization. As part of this procedure, his doctor intentionally induced arrhythmias. O'Neal filed a workers' compensation claim based on the arrhythmias and listed June 26th as the date of the accident. Later, the doctor testified broadly that job stress could play a role in causing arrhythmias, but could not implicate job stress in the development of O'Neal's condition, instead, he stated that his understanding of the condition was that it had been triggered by elite level exercise.

After the initial hearing, the JCC determined that the claim was compensable under the correctional officer's occupational causation presumption in §112.18(1)(a) Fla. Stat. The JCC acknowledged that the atrial tachycardia was congenital, and concluded that his heart problems were a compensable injury that could have been triggered by job-related stressors. O'Neal's employer and insurance carrier (together E/C) appealed, and the appellate court reversed and remanded for additional findings related to the trigger-theory-based decision of the JCC. The court asked the JCC to identify the underlying condition and resulting diagnosis so the scope of E/C's potential liability could be determined. The JCC affirmed that the diagnosis was atrial tachycardia that degenerated into atrial fibrillation and concluded under the occupational presumption that his employment could have triggered the degeneration. E/C appealed again.