Summary
This Tennessee Workers' Compensation Appeals Board decision reviews a trial court's award of death benefits to the surviving spouse of a truck driver who died of a heart attack while securing his load following a police traffic stop. The employer appealed, arguing the employee's pre-existing conditions were the primary cause and that the traffic stop did not constitute an unusual mental stressor. The Board affirmed the lower court's ruling, finding substantial evidence supported the claimant's expert cardiologist's opinion that the combination of physical exertion and acute emotional stress primarily caused the fatal cardiac event.
Topics
Practice areas
Questions Presented
- Whether the evidence supported the trial court's determination that Taylor's death primarily arose out of and in the course and scope of his employment.
- Whether the traffic stop constituted an abnormal or unusual mental stressor sufficient to contribute causally to Taylor's fatal cardiac event.
- Whether the trial court properly relied on the claimant's cardiologist's opinion over the employer's contrary medical opinion.
Holdings
- The evidence did not preponderate against the trial court's finding that Taylor suffered a fatal cardiac event primarily caused by the emotional stress of the traffic stop combined with the physical exertion required to secure the load; the award of death benefits was therefore supported.
- The evidence supported the finding that this particular traffic stop was an abnormal or unusual mental stressor rather than merely an ordinary stress of employment for a commercial truck driver.
- The absence of an autopsy did not defeat the claim where the medical proof established that a sudden cardiac event was the probable cause of death.
Key quotations
“Thus, although reasonable minds may differ as to whether a traffic stop for a truck driver is abnormal or unusual, we conclude the evidence does not preponderate against the court’s determination that Employee suffered a fatal heart attack primarily caused by the emotional stress of the traffic stop combined with the physical exertion associated with climbing into the trailer to secure the load.” (9-10)
“Thus, while it still makes no difference that the employee, prior to the heart attack, suffered from pre-existing heart disease or that the heart attack was precipitated by the usual physical strain of the employee’s job, the proof must now establish the heart attack arose primarily from the employment considering all causes.” (6)
Factual background
Darrell Taylor, a truck driver for Dale's Recycling, was stopped by a deputy after scrap metal fell from his trailer and struck another vehicle. At the deputy's direction, Taylor climbed into the trailer to rearrange the load; approximately five to ten minutes later, the deputy found him unresponsive and emergency personnel confirmed his death. The coroner listed cardiorespiratory arrest due to chronic hypertension, with diabetes as a significant condition, while competing cardiologists disagreed whether the death was primarily caused by preexisting disease or by the combination of physical exertion and the emotional stress of the traffic stop.
Procedural history
After Darrell Taylor died during a work-related traffic stop, his surviving spouse filed a Petition for Benefit Determination seeking workers' compensation death benefits. The trial court accepted the claimant's cardiologist's causation opinion over the employer's contrary expert opinion and awarded benefits. The employer appealed, arguing that the death was primarily caused by preexisting medical conditions and that the traffic stop was not an abnormal or unusual mental stressor.