Did Deputy’s Pursuit of Armed Suspect Trigger Heart Attack?

What Do You Think?

Some workers have such stressful jobs that it’s easy to picture their heart stopping at work or at least skipping a beat.

But is a heart attack compensable simply because an employee works in a stressful job and his heart promptly fails him after carrying out a stressful task? That issue arose in the case of a police officer who had chest pain after tailing an armed suspect.

The deputy sheriff had a history of smoking, but had quit. He apparently had a diet that was not heart-friendly. But he also had a job filled with stressful events. He testified that getting a suspect out of a car and putting them on the ground was common. 

On the night of Oct. 28, 2023, he was in his squad car pursuing an armed suspect, who was then taken into custody. Shortly afterward, he started having chest pain with shortness of breath. The next day he went to the hospital and learned that he had had a heart attack.

He filed workers’ compensation claim. He didn’t provide a doctor’s testimony or other medical evidence connecting his job to his heart attack. The claim administrator and board denied the claim. The sheriff appealed. 

The appeals court stated that for a claim to be compensable, three elements must coexist: (1) a personal injury, (2) received in the course of employment, and (3) resulting from that employment.

Did the deputy's injury result from his job?

A. Yes. The nature of the job and the fact that the symptoms of the attack began right after the sheriff's pursuit of the suspect showed the two were related.

B. No. Without medical evidence showing the job caused the heart attack, it was just as likely that his diet or past smoking sparked the attack.

If you selected B, you agreed with the court in Willis v. Fayette County Comm’n, No. 25-ICA-46 (W. Va. Inter. Ct. App. 08/29/25), which held that the sheriff failed to show that his heart attack resulted from his job.

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The court pointed out that for an injury to result from employment, there has to be a causal connection between the injury and employment. The board did not clearly make a mistake by finding that there was no such connection. The sheriff didn’t present any medical evidence to show that his job, rather than his lifestyle, caused his heart attack. Under the circumstances, it would have been pure speculation to find that there was a causal link.

The court affirmed the board’s finding that the claim was not compensable.

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