Florida's Correctional Officer Presumption and Olympic Level Training

The US Court of Appeals for the Eighth Circuit in Florida has ruled that the Judge of Compensation Claims (JCC) erred in entering a judgment in favor of a corrections officer for a cardiac injury because medical evidence showed that strenuous exercise triggered the degeneration of his congenital heart condition into atrial fibrillation. The case is City of Jacksonville v. O’Neal, No. 1D19-597, 2020 Fla. App. LEXIS 5471 (Dist. Ct. App. Apr. 23, 2020).

In 2002, Adrian O’Neal, the claimant, was a twenty-nine-year-old corrections officer who began experiencing heart problems. Reportedly, when exercising, O’Neal’s heart would flutter, causing lightheadedness. At that time, he was training to participate in Olympic-type track and flag-football competitions. He sought medical advice for his heart issues, and was diagnosed with atrial tachycardia and atrial fibrillation. On June 26th of that year, O’Neal underwent a cardiac catheterization. As part of this procedure, his doctor intentionally induced arrhythmias. O’Neal filed a workers’ compensation claim based on the arrhythmias and listed June 26th as the date of the accident. Later, the doctor testified broadly that job stress could play a role in causing arrhythmias, but could not implicate job stress in the development of O’Neal’s condition, instead, he stated that his understanding of the condition was that it had been triggered by elite level exercise.