Estacada Rural Fire Dist. #69 v. Hull

When a physical disorder is caused by a stress-related mental disorder, the firefighters’ presumption does not apply. Stress-related physical disorders are not compensable under workers compensation claims unless heightened standards are met.

Claimant, a fire district chief, filed for worker’s compensation after experiencing a heart attack, potentially due to the stress of going undercover for the sheriff’s office to gather evidence of embezzlement. Claimant argued that the heart attack was a compensable occupational disease. Claimant argued that the firefighters’ presumption applied to the determination of whether the heart attack was compensable, as opposed to the stricter-standard used for a mental disorder claim. The Workers' Compensation Board agreed with Claimant and applied the firefighters' presumption. On judicial review, Employer argued that when a cardiovascular disease is caused by a stress-related mental disorder, the firefighters’ presumption does not apply. The Court reviewed the legislative history of the firefighters’ presumption to determine the original intent and found support in favor of Employer's position. Legislative history indicated that stress caused by everyday work situations, faced by employees in any job, were not considered as part of the firefighters’ presumption. Furthermore, legislative history in support of the firefighters' presumption concerned the emotional and physical strain associated with fighting fires and rescuing people from dangerous situations. For these reasons, the Court held that the board erred in applying the firefighters’ presumption when a physical disorder is caused by a stress-related mental disorder. Reversed and remanded.