A Florida court has ruled on a significant case involving a firefighter's workers' compensation claim for heart disease. The District Court of Appeal of Florida decided on October 7, 2026, that the City of Maitland and its insurance provider, Davies Claims North America, Inc., must compensate William McGovern for his heart condition. This ruling is important as it clarifies the responsibilities of employers under workers' compensation laws, especially in cases involving occupational diseases like heart disease.
The case, officially known as City of Maitland v. McGovern (Docket No. 1D2025-2729), centers around a firefighter who developed serious heart issues after years of service. The ruling impacts not only McGovern but also sets a precedent for other firefighters and public safety workers facing similar health issues.
Background
William McGovern began his career as a firefighter for the City of Maitland in 1988. He passed a preemployment physical at that time, showing no signs of heart disease. However, in June 2012, McGovern underwent a cardiac stenting procedure after doctors discovered significant blockage in his heart. Following this procedure, he retired from Maitland in August 2012 without initially filing a workers' compensation claim for his heart condition.
After retiring, McGovern took a job with the Sanford Airport Authority (SAA), where a preemployment physical revealed evidence of heart disease. In 2024, he experienced further heart complications, which led to additional surgeries and placement on a heart transplant list. This prompted him to file a petition for benefits against Maitland and Davies Claims North America, claiming that his heart condition was compensable under workers' compensation laws.
The City of Maitland and its insurance provider argued that SAA should be responsible for McGovern's heart condition under the last injurious exposure rule. This rule states that the employer where an employee was last exposed to the hazards of an occupational disease is liable for the claim. The case was brought before the judge of compensation claims (JCC), who ruled in favor of McGovern.
The Ruling
The District Court of Appeal upheld the JCC's decision, affirming that McGovern's heart disease was compensable under Florida law. The court noted that the JCC had determined that the presumption of occupational causation for heart disease, as outlined in section 112.18(1) of the Florida Statutes, applied to McGovern's case. The court stated, "The presumption created by section 112.18 did not apply to his employment there." This ruling indicates that because McGovern had heart disease before working at SAA, the presumption of causation could not be applied to that employment.
The court also rejected Maitland's argument that they should not be held responsible for the claim. The judges pointed out that McGovern's preemployment physical with SAA showed evidence of heart disease, which meant that the last injurious exposure rule did not apply. The court concluded that the JCC did not err in denying Maitland's claim for contribution from SAA. The judges, M.K. Thomas, Treadwell, and Lewis, all concurred with the ruling.
Impact
This ruling is significant for several reasons. It clarifies the responsibilities of employers regarding workers' compensation claims for occupational diseases, particularly heart disease among firefighters. The decision reinforces the importance of the presumption of causation for heart disease under Florida law, which is designed to protect firefighters and other first responders who face health risks due to their occupations.
Going forward, this ruling may influence how similar cases are handled in Florida. It emphasizes that employers must be prepared to demonstrate that a firefighter's heart disease is not compensable if they wish to avoid liability. This case could set a precedent for future claims involving occupational diseases, ensuring that firefighters receive the benefits they deserve for conditions developed during their service.
What's Next
Details were not available in the court filing regarding whether this ruling can be appealed. However, the decision is not final until the disposition of any timely and authorized motion under Florida Rules of Appellate Procedure. There are no related cases pending at this time.