Summary
The Connecticut Supreme Court held that hypertension and heart disease are separate diseases under General Statutes § 7-433c, each subject to its own one-year claim limitation period. The court affirmed an award of heart disease benefits to Reginald Holston because his claim, filed shortly after his myocardial infarction, was timely even though his earlier hypertension claim was untimely.
Topics
Practice areas
Questions Presented
- Whether a prior untimely claim for hypertension bars a later claim for heart disease under General Statutes § 7-433c.
- Whether hypertension and heart disease must be treated as separate diseases, each subject to its own one-year limitation period, under § 7-433c.
- Whether the commissioner and Review Board improperly applied proximate-causation principles or denied the defendant's motion to correct.
Holdings
- A failure to file a timely claim for benefits related to hypertension does not bar a later timely claim for benefits related to heart disease when the claimant otherwise satisfies the statutory requirements.
- Holston was entitled to § 7-433c heart disease benefits because he passed a preemployment physical that revealed no hypertension or heart disease, suffered a disabling condition caused by heart disease, and filed his heart disease claim within four days of its manifestation.
- Section 7-433c does not require the claimant to prove that heart disease was causally connected to employment; therefore, alleged errors concerning proximate-causation rules were irrelevant and the denial of the motion to correct was proper.
Key quotations
“Furthermore, the use of the disjunctive term "or" in § 7-433c indicates that the legislature intended for hypertension and heart disease to be treated as two separate diseases for the purposes of § 7-433c.”
“Accordingly, we conclude that the plain language of the statute demonstrates that the failure to file a timely claim for benefits related to hypertension does not bar a later timely claim for heart disease.”
Factual background
Reginald Holston was hired as a New Haven police officer in 1996 after passing a preemployment physical that revealed no hypertension or heart disease. He was diagnosed with hypertension in October 2009 and suffered a myocardial infarction on March 10, 2011, after which he underwent angioplasty and stent implantation and experienced continuing disability. He filed a § 7-433c claim on March 14, 2011; the commissioner found the hypertension claim untimely but awarded benefits for heart disease, which the Review Board affirmed.
Procedural history
Holston filed a claim for hypertension and heart disease benefits after suffering a myocardial infarction. The Workers' Compensation Commissioner dismissed the hypertension claim as untimely but awarded benefits for heart disease; the Review Board affirmed. The defendant appealed, and the Supreme Court affirmed the Board's decision.