Heart Rhythm Hiccups Support Fla. Firefighter’s Heart-Lung Claim

Case File

A firefighter’s heart-rhythm disorders qualified as “heart disease” under Florida’s heart-lung statute, the Florida First District Court of Appeal held. This entitled the firefighter to the statute’s presumption that the injuries arose out of her job.

Case

Village Center Community Development District v. Illeck, No. 1D2025-3075 (Fla. Dist. Ct. App. 09/23/26)

What Happened

Chelsea Illeck, a full-time firefighter, experienced chest pain, shortness of breath, and a racing heart while transporting a patient. At the hospital, she was diagnosed with supraventricular tachycardia (SVT), an abnormal heart rhythm.

Illeck reported her heart injury in April 2025 and sought workers’ compensation benefits under Florida’s heart-lung statute, § 112.18. That statute creates a presumption that an injury is work-related. The employer denied the claim, asserting that the presumption did not apply because the SVT and atrial tachycardia (AT) did not fit the definition of a heart condition articulated by the appeals court in another case, North Collier Fire Control & Rescue District v. Harlem, 371 So. 3d 368 (Fla. Dist. Ct. App. 2023). That case defined heart disease as a problem of the heart’s “plumbing” system, such as hypertension that weakens the heart muscle. Ileck, the employer argued, had a disease of the heart’s electrical system, and thus her conditions were not covered by the statute.

The JCC found that the employee’s conditions constituted a heart disease and qualified for the statutory presumption. The JCC pointed out that both sides’ cardiologists agreed that Illeck’s SVT and AT constituted heart disease. Further, the employer’s IME physician testified that the conditions could be debilitating and could weaken the heart muscle. The employer appealed. 

Rule of Law

Under Florida’s heart-lung statute, § 112.18(1), when a qualifying firefighter becomes disabled by “heart disease,” there is a statutory presumption that she incurred the condition in the line of duty.

What the Florida 1st DCA Said

The appeals court rejected the employer’s argument that North Collier limited “heart disease” to conditions involving arteries, valves, and blood pressure. The definition used in Harlem was tailored to the medical condition at issue in that case and was not meant to be exhaustive. In fact, the appeals court pointed to a long line of cases recognizing conditions such as SVT, atrial fibrillation, tachycardia, and other cardiac arrhythmias as heart disease for purposes of § 112.18. Because the medical evidence established that Illeck’s SVT and AT were diseases of the heart’s electrical system, the court found no error in the JCC’s award of benefits. 

Verdict: The Florida First District Court of Appeal affirmed the award of benefits to the firefighter. 

Takeaway

Heart disease under the heart-lung statute is not limited to diseases involving clogged coronary arteries, high blood pressure, or heart valves. Disorders involving the heart’s electrical system may also constitute heart disease.

The case limits Florida employers’ and carriers’ ability to point to Harlem to defend themselves against heart-lung claims. Harlem does not establish an exhaustive definition of “heart disease,” confining the presumption to conditions involving coronary arteries, hypertension, or valves. A disorder of the electrical system can also qualify as heart disease under the statute.

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