Coughlin v. Stamford Fire Dept., 334 Conn. 857

John Coughlin, a Stamford firefighter hired in 1975, filed a §7-433c claim for hypertension with a January 28, 2011 date of injury while still employed.
Coughlin retired April 5, 2013. The Workers’ Compensation Commissioner found his hypertension claim compensable on March 22, 2016.
Dr. Donald Rocklin subsequently assigned a 6% permanent partial heart disability (May 21, 2016) and diagnosed coronary artery disease in reports concluding that Coughlin’s hypertension was a significant factor in developing that disease.
Coughlin sought benefits for coronary artery disease; the commissioner denied that claim, reasoning the coronary disease was diagnosed after retirement and that Rocklin’s opinion did not establish compensability under §7-433c.
The Compensation Review Board reversed, holding that a cardiac condition developing as a sequela of a compensable §7-433c hypertension claim can be compensable without a new notice if causation is established.
The Supreme Court affirmed the board: where an initial §7-433c claim is timely and compensable, subsequent heart disease that is causally connected to that hypertension may be compensable even if diagnosed after retirement, and unchallenged expert opinion establishing causation sufficed here.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether heart disease diagnosed after retirement is time-barred under §7-433c	Coughlin: heart disease flowed from his compensable hypertension claim, so no new timely claim/notice required	Stamford: diagnosis and disability occurred after retirement, so not compensable under §7-433c	Held: Post-retirement heart disease can be compensable if it is a sequela of a compensable §7-433c injury and causation is proven
Whether heart disease must be treated as a separate, new injury requiring a new claim	Coughlin: statute and act permit compensation for sequelae of a compensable primary injury without new notice if causation exists	Stamford: §7-433c treats hypertension and heart disease as separate diseases; a new, distinct claim is required	Held: §7-433c does not bar compensation for subsequent heart disease that flows from a compensable hypertension claim; the Act’s causation rules govern sequelae claims

Holston v. New Haven Police Dept., 149 A.3d 165 (Conn. 2016) (sets out §7-433c eligibility elements and discusses relation of hypertension and heart disease)
Sapko v. State, 44 A.3d 827 (Conn. 2012) (explains compensability of subsequent injuries that are direct and natural results of compensable primary injuries)
Marandino v. Prometheus Pharmacy, 986 A.2d 1023 (Conn. 2010) (requires expert medical evidence to establish causal link for sequelae)
Ciarlelli v. Hamden, 8 A.3d 1093 (Conn. 2010) (one-year limitation from §31-294c governs §7-433c claims)
Felia v. Westport, 571 A.2d 89 (Conn. 1990) (once §7-433c coverage established, benefits measured identically to Workers’ Compensation Act)
Carter v. Clinton, 41 A.3d 296 (Conn. 2012) (late-notice condition may be allowed when causally related to a timely reported incident for which employer furnished medical care)