Mechanicsburg, PA (WorkersCompensation.com) – When an employee has a fatal heart attack on the job, the event may or may not be job-related for purposes of workers’ compensation benefits. As one case shows, the outcome often comes down to a battle of medical experts.
A dispute following a truck driver’s death at work on May 15, 2017, is a case in point. The driver’s ex-wife filed a death benefits claim on behalf of their children. She claimed the injury was causally related to the stress and physical exertion of the job.
She presented the testimony of a doctor who, though he had not treated the decedent, reviewed the relevant records. Those records included the autopsy report and an internet search indicating that a truck driver’s job is highly stressful due to extended time driving, sleep deprivation, and the necessity of handling a large steering wheel, and hitching and unhitching the trailer.
The doctor did not speak to anyone in the decedent’s family regarding either the driver’s job duties or his lifestyle. He based his opinion on a generic job description obtained from the internet rather than information provided by the employer.
The employer introduced its own medical expert, who relied on the company’s driving logs and load sheet, and the autopsy report and medical records. The logs indicated the decedent worked as follows:
| Date | Work hours |
| March 13 | Drove for 6 hours and was off duty at 9:30 p.m. |
| March 14 | Drove for 10 hours that day and was off at 9:00 p.m. |
| March 15 | Began work at 7:00 a.m. and drove 2 hours before reaching Chicago at 1:00 p.m |
The autopsy report and medical records revealed that the decedent had significant long standing hypertension and a longtime smoking habit. The records showed that he had a ten-point blockage in an artery, an enlarged heart, and a history of silent heart attack. The employer’s medical expert opined that the decedent’s fatal heart attack was caused by his long-standing, preexisting conditions of untreated high blood pressure, smoking, and being overweight.
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The load sheet documenting the information for the final delivery stated that it was “no touch,” meaning the driver did not have to assist in loading or unloading the order.
The court explained that in the context of a fatal claim petition, the surviving family member must demonstrate, in part, that the injury “was a substantial contributing cause in bringing about the death of that employee.”
Was the claimant entitled to death benefits?
A. No. The medical evidence indicated that the driver’s pre-existing conditions, not his truck driving duties, were to blame for his heart attack.
B. Yes. The physical stress of truck driving caused the driver’s heart attack.
If you selected A, you agreed with the court in Dnistranskiy v. Brite Logistics, Inc., No. 414 C.D. 2023 (Pa. Commw. Ct. 05/10/24, unpublished), which held that the driver’s ex-spouse was not entitled to benefits.
In order for a decedent’s fatal heart attack to be compensable, the court noted, the claimant had to establish through medical evidence that the heart attack was causally related to the decedent’s employment.
Here, the medical testimony wasn’t sufficient to establish such a link. While the ex-spouse’s medical expert pointed to sleep deprivation as one factor, “the logs showed that the decedent slept, or at least was not driving, for 12 hours on the evening of March 13, 2017, and for 10 hours on the evening of March 14, 2017,” the court wrote.
Further, while the claimant’s expert opined that the hitching and unhitching of the load the decedent was hauling was a substantial contributing factor, there was no evidence that the decedent performed those tasks. Further, the doctor never asked the employer about the specifics of the driver’s duties, but instead relied on a generic description of a truck driver’s job.
Finally, the evidence showed that the driver had significant risk factors for a heart attack, including hypertension and smoking. The employer’s expert’s contention that it was these factors that caused the heart attack were more convincing than the opinions of the claimant’s expert.
The court affirmed the denial of the claim.
