Page 30 - CLT032320

30 ¦ MARCH 23, 2020 CONNECTICUT OPINIONS

SUPREME COURT Court Determined Claims for
Subsequent Medical Condition
Were Compensable Where Causal
ADMINISTRATIVE LAW • LABOR LAW Connection to Initial Compensable

Court Affirmed Decision to Vacate Claim Existed
Dismissal of Plaintiff’s Claim for
CASE: Coughlin v. Stamford Fire Dep’t
COURT: Connecticut Supreme Court
Medical Benefits DOC. NO.: SC 20319
COURT OPINION BY: Kahn
CASE: Dickerson v. City of Stamford
COURT: Connecticut Supreme Court
DOC. NO.: SC 20244 DATE: March 10, 2020 • PAGES: 10
COURT OPINION BY: Kahn Plaintiff, a former firefighter, filed a claim
DATE: March 10, 2020 • PAGES: 8 for hypertension benefits while employed.
After plaintiff retired, the Workers’ Com-
Plaintiff was diagnosed with hypertension pensation Commissioner concluded the
while working as a police officer and in 2004, plaintiff ’s hypertension claim was com-
the Workers’ Compensation Commissioner pensable. Plaintiff ’s doctor then diagnosed
determined it was compensable. Plaintiff re- plaintiff with coronary artery disease and
tired and then suffered a myocardial infarc- concluded that plaintiff ’s hypertension was
tion. He filed for compensation, but his claim a significant factor in the development of
was dismissed. The Compensation Review that disease. Plaintiff pursued compensation
Board vacated the Workers’ Compensation for the disease but the commissioner did not
Commissioner’s dismissal of plaintiff ’s claim find the claim compensable and dismissed it.
for benefits under a statute governing com- The Compensation Review Board reversed
pensation for police officers with hyperten- the commissioner’s decision, finding that a
sion or heart disease. The city appealed and cardiac event occurring subsequent to an
the court affirmed. The court held that plain- initial compensable injury is not necessar-
tiff satisfied the jurisdictional prerequisites ily a new injury that would require the fil-
of the state and was not required to file no- ing of a new claim. Defendant appealed and
tice of a new claim in order to get benefits for
his heart disease. Therefore, the court upheld the court affirmed. The court held that the
the board’s decision to vacate the dismissal claim for heart disease that occurs after an
of plaintiff ’s claim for benefits. The court initial compensable claim for hypertension
also determined that a claimant who suffers a may qualify for benefits without a new claim
compensable primary injury can also be com- as long as there is a causal connection be-
pensated for a subsequent injury when that tween the two conditions, and a retiree can
injury is the direct and natural result of the pursue this claim of heart disease even after
compensable primary injury. Therefore, the retirement. Therefore, the court affirmed the
court affirmed. review board’s reversal.

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