A Florida court recently ruled that atrial fibrillation (AFib) qualifies as heart disease under the state's workers' compensation law. This decision affects firefighter Joseph Durden, who sought benefits after being diagnosed with AFib. The court's ruling is significant as it clarifies the interpretation of heart disease in the context of workers' compensation claims for first responders.

The case, Durden v. St. Johns County Fire Rescue, Preferred Governmental Claims Solutions, was filed under docket number 1D2024-1623. The ruling came from the First District Court of Appeal of Florida on November 4, 2026. The decision is crucial for firefighters and other first responders who may suffer from heart-related conditions while on duty.

Joseph Durden began his career with St. Johns County Fire Rescue in 2007, serving as a firefighter and paramedic. On August 24, 2023, while on vacation, he experienced heart palpitations and a rapid, irregular pulse. After seeking medical attention, he was diagnosed with AFib and treated accordingly. Following his diagnosis, Durden applied for workers' compensation benefits, requesting coverage for temporary disability, cardiology treatment, and payment for emergency hospital care.

During the final hearing, the employer and carrier acknowledged that Durden had no prior evidence of AFib during his preemployment physical examination. They conceded that he met the statutory requirements for disability benefits if AFib was classified as heart disease. The primary issue for the court was whether AFib fell under the definition of heart disease as outlined in Florida's heart-lung statute, section 112.18.

Two independent medical examiners testified that AFib is indeed a form of heart disease. Dr. David Perloff, who examined Durden, and Dr. Steven Borzak, representing the employer/carrier, both described AFib as an electrical disorder affecting the heart's normal function. Despite the absence of structural damage to Durden's heart, they agreed that AFib interfered with its normal operation.

However, the judge of compensation claims (JCC) ruled against Durden, referencing a prior case, North Collier Fire Control and Rescue District v. Harlem. In that case, the JCC had defined heart disease as conditions that weaken the heart through degradation of its vessels or valves. Since Durden's AFib did not fit that description, the JCC denied his claim for benefits.

The First District Court of Appeal reviewed the case and concluded that the JCC's interpretation was too narrow. The court examined the original meaning of “heart disease” as it was defined at the time the statute was enacted in 1965. They noted that the term was not explicitly defined in the statute, leading to ambiguity in its application.

The court cited historical medical definitions, including a 1957 edition of Dorland’s Illustrated Medical Dictionary, which defined heart disease as any condition affecting the heart's function, regardless of structural damage. The court emphasized that AFib, as a functional disorder, fits within this original understanding of heart disease.

In their ruling, the court stated, "Durden’s AFib therefore falls within the original meaning of 'heart disease' under section 112.18." They determined that the JCC had misapplied the precedent set in Harlem, which did not adequately encompass functional disorders like AFib. The court highlighted that AFib disrupts the heart's electrical activity, qualifying it as heart disease for the purposes of workers' compensation.

The court ultimately set aside the JCC's denial of compensability for Durden's AFib and related benefits, remanding the case for further proceedings. They clarified that the separate denial of compensability for hypertension, which Durden did not challenge, remained unaffected by this ruling.

This ruling has significant implications for firefighters and first responders in Florida. It establishes that conditions like AFib, which may not show structural damage but still affect heart function, are compensable under the workers' compensation law. This decision may encourage other first responders with similar conditions to seek benefits, knowing that their claims could be supported by this legal precedent.

Looking ahead, the case could potentially be appealed, although the court did not specify any immediate plans for further legal action. The ruling also opens the door for other firefighters facing similar health issues to pursue their claims under the clarified definition of heart disease.

As the legal landscape continues to evolve regarding workers' compensation for first responders, this case reinforces the importance of recognizing various heart conditions as legitimate claims under the law. It highlights the need for ongoing discussions about how best to support those who serve in high-risk occupations.