Court Says Irregular Heartbeat Counts as Heart Disease

Florida's appeals court sets aside a firefighter's workers' compensation denial for atrial fibrillation.

Updated on Nov. 6, 2026 in Heart Disease

Court Says Irregular Heartbeat Counts as Heart Disease

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Florida's First District Court of Appeal set aside a workers' compensation denial for a St. Johns County firefighter diagnosed with atrial fibrillation, ruling the condition is covered as heart disease under the state's heart-lung presumption statute. The decision was issued November 4, 2026.

Why it matters

The ruling clarifies that electrical heart disorders can qualify for Florida's heart-lung presumption, not only conditions that structurally weaken the heart. Florida residents who serve as firefighters or in similar public safety roles may see the decision shape how future claims are evaluated.

The ruling is an appellate decision in a workers' compensation claim under Florida Statute section 112.18, with the firefighter's service dating to 2007 and diagnosis on August 24, 2023. The court relied on a 1957 medical dictionary definition of heart disease, and it is unresolved whether the remaining benefit issues will be contested further.

The players

St. Johns County Fire Rescue

The St. Johns County public fire and rescue agency employed the firefighter since 2007 and is the employer in the workers' compensation claim.

Preferred Governmental Claims Solutions

The workers' compensation carrier for the employer that contested the firefighter's claim, which acknowledged a clear pre-employment physical.

First District Court of Appeal

Florida's intermediate appellate court whose decision set aside the compensation judge's denial and reinterpreted the heart-lung statute.

The details

A St. Johns County firefighter woke with heart palpitations and an irregular pulse while on vacation and was diagnosed with atrial fibrillation. The compensation judge denied the claim based on North Collier Fire Control and Rescue District v. Harlem, but the appellate court found that case involved a different organ and question.

1957: A medical dictionary defined heart disease to include functional conditions of the heart.
1965: The Florida Legislature enacted the heart-lung statute without defining heart disease.
2007: The firefighter began service with St. Johns County Fire Rescue.
August 24, 2023: The firefighter experienced palpitations and was diagnosed with atrial fibrillation.
November 4, 2026: The First District Court of Appeal set aside the denial.

Health Landscape

The decision sits within Florida's heart-lung presumption under section 112.18, a 1965 statute that presumes heart conditions in public safety workers are work-related. By recognizing atrial fibrillation as covered heart disease, the court moves the statute's application beyond structural heart damage toward a broader reading of functional cardiac conditions.

Firefighters and other public safety workers in Florida who develop heart rhythm disorders may now have a clearer path to having those conditions recognized under the heart-lung presumption. Workers with atrial fibrillation or similar electrical conditions should be aware that such claims are not automatically barred by the absence of structural heart damage.

The takeaway

Public safety workers in Florida should know that an irregular heartbeat can qualify as heart disease under the state's heart-lung presumption, even without structural damage to the heart. Anyone considering a workers' compensation claim for a heart condition should review how the statute has been applied in recent appellate decisions.