JCC Denies Heart-Presumption Claim for Atrial Fibrillation

In Hilcken v. Martin County Sheriff's Office / Florida Sheriffs Risk Management Fund, OJCC Case No. 25-026655GJJ, Judge Gregory J. Johnsen considered whether a deputy's atrial fibrillation was compensable under the section 112.18 heart-disease presumption.

The JCC accepted that the claimant had an AFib event resulting in hospitalization, but found he did not prove every element needed to invoke the statutory presumption. The missing element was proof that he successfully underwent a pre-employment physical upon entering service as a law enforcement officer that revealed no evidence of heart disease.

Because the claimant relied solely on the presumption to establish compensability, the JCC denied the AFib compensability claim, related specialist and primary-care authorization, the prescription bill, fees, and costs, and dismissed the petition with prejudice.

Source: Final Compensation Order