Court Upholds Decision That Firefighter’s Obesity, Not Job, Caused Heart Attack

Curtis Simpson, a firefighter with Peoria, Illinois, filed a workers’ compensation claim alleging work-related permanent injury to his heart by virtue of a heart attack. A front-line duty firefighter for 22 years, Simpson had an extensive history of exposure with regard to fire, smoke, and other toxins, his demolition of buildings, high-stress situations, and noise.

Simpson became an administrative officer in 1997 and worked in this capacity until the end of his career. Simpson later testified that there was a good deal of stress involved when he assumed Battalion Chief and became responsible for the safety of 60 firefighters.

On January 12, 2008, at the age of 63, Simpson was home sweeping and cleaning his garage. He felt some moderate pain, and ended up at an emergency room. A doctor diagnosed a heart attack. Simpson did not have a family history of cardiovascular disease, had never been a smoker, and his alcohol use was minimal. Simpson was awarded a duty-related pension, but continue pursuing his workers’ compensation claim.

The Illinois Workers’ Compensation Commission ruled against Simpson, finding that the City had successfully rebutted the presumption that Simpson’s cardiovascular disease was causally related to his employment as a firefighter. Simpson appealed the denial.

The Illinois Court of Appeals upheld the denial of Simpson’s claim. The Court observed that it would only overturn a factual finding by the Commission if the finding was “against the manifest weight of the evidence and an opposite conclusion is clearly apparent. Applying that standard here, we cannot say that an opposite conclusion is clearly apparent. The Commission was very specific in its decision as to its reasoning and its findings regarding the evidence. It found Dr. Fintel’s opinion to be more credible than that of Dr. Weaver because it found Dr. Fintel, as a cardiologist, is better credentialed and possessed a greater foundational understanding of Simpson’s condition. Dr. Fintel testified that the claimant’s risk factors, including his gender, obesity, age, poor diet, and high cholesterol were the causes of the claimant’s condition.

“In reviewing the decision of the Commission, we give deference to its determinations resolving conflicts in the evidence or regarding credibility of witnesses and the weight that their testimony is to be given. For these reasons, we decline to disturb the Commission’s determination.”

Simpson v. Illinois Workers’ Compensation Commission, 2017 IL App (3d) 160024WC (Ill. App. 2017).