James Lane is a detective with the City of Cookeville, Tennessee Police Department. On the morning of June 6, 2004, Lane suffered a heart attack.
During the week prior to his heart attack, Lane was “on call.” This meant that he worked a regular shift from 1:45 p.m. to 10:00 p.m. Monday through Friday, and went to work at other times as the need arose. He had worked 21 hours of on-call overtime during the week in question.
On June 5, Lane was called out at 1:00 a.m. to investigate an aggravated assault. The incident involved several people who spoke only Spanish. Lane testified that the investigation was “nerve wracking” because of the language barrier.
Lane was then called upon to investigate a rape complaint. He went to the hospital and met the victim, who was later taken by someone else to the Department, where Lane interviewed her. The victim was “very upset, emotional, crying.” Lane did not come into contact with any suspects and was not threatened in any way during that investigation.
At 1:30 a.m. on June 6, Lane was called to the hospital to investigate a case of potential child abuse. A woman had an automobile accident as the result of driving while intoxicated. Her child had been a passenger in the vehicle and was injured in the wreck. Lane took photographs of the child and assisted other agencies in investigating the case. Lane testified that while he was at the hospital, he began having “strong heartburn pain” in his chest.
When Lane sought workers’ compensation benefits for his heart attack, his application was denied by the City. A “special workers’ compensation appeals panel” of the Tennessee Supreme Court upheld the City’s denial of Lane’s request for benefits.
The Court found that a heart attack may be compensable if it is caused either by the physical exertion of working or by mental or emotional stimulation. Since Lane had not engaged in any physical exertion, the question was whether he could prove that the stress of the job caused his heart attack. Moreover, the Court ruled that Lane would have to prove that “the events which precipitated the heart attack are sufficient to constitute an accidental injury as contemplated by the principles of the workers’ compensation law.”
The Court cited the fact that Lane acknowledged that none of the cases which he investigated on June 5 and 6, 2004, presented particularly dangerous or threatening circumstances: “He had investigated similar cases on many previous occasions, but perhaps not all within a 36-hour period. Lane contends that the combination of three difficult cases in a short period of time should make his heart attack compensable. However, by his own description, none of the investigations involved confrontations or other threatening circumstances. We conclude that the events described by Lane were not sufficiently acute, sudden, unusual, or abnormal when compared to the normal stresses of his job as a police detective to render the heart attack an accidental injury under our workers’ compensation law.”
Lane v. City of Cookeville, 2007 WL 2284862 (Tenn.App. 2007).
This article appears in the October 2007 issue