Holston v. New Haven Police Dept.
149 A.3d 165
| Conn. | 2016Background
- Holston was hired as a New Haven police officer in 1996 after a preemployment physical that showed no hypertension or heart disease.
- In October 2009 Holston was diagnosed with hypertension by his treating physician and was informed of that diagnosis.
- On March 10, 2011 Holston suffered a myocardial infarction, underwent angioplasty and stent placement, was hospitalized, prescribed cardiac medications, and was out of work for months.
- Holston filed a § 7-433c claim on March 14, 2011 for both hypertension and heart disease; the commissioner held the hypertension claim untimely but granted the heart disease claim.
- The Workers’ Compensation Review Board affirmed; the employer appealed to the Supreme Court challenging whether a prior hypertension diagnosis barred a later heart disease claim under § 7-433c.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a timely § 7-433c claim for heart disease can proceed where the claimant previously was diagnosed with hypertension more than one year earlier | Holston: § 7-433c treats ‘‘hypertension or heart disease’’ disjunctively; separate diseases have separate limitation periods, so the heart disease claim filed days after the MI is timely | New Haven: Because hypertension was a significant contributing cause of the heart disease, the one-year limitation tied to the earlier hypertension diagnosis should bar the later heart disease claim | Court: Affirmed board — § 7-433c’s disjunctive language treats hypertension and heart disease as separate for claim-timing; prior untimely hypertension claim does not bar a timely heart disease claim |
| Whether § 7-433c requires proof that the disease was caused by employment (proximate causation) | Holston: § 7-433c provides a rebuttable presumption/bonus and does not require proof of employment causation | New Haven: Sought to apply proximate causation rules (via motion to correct) | Court: § 7-433c does not require causation proof tied to employment; motion to correct properly denied as causation rules are inapplicable |
Key Cases Cited
- Ciarlelli v. Hamden, 299 Conn. 265 (2010) (one-year limitation of § 31-294c governs § 7-433c claims)
- Malchik v. Division of Criminal Justice, 266 Conn. 728 (2003) (§ 7-433c creates a rebuttable presumption/bonus and does not require employment causation)
- Carriero v. Naugatuck, 243 Conn. 747 (1998) (explaining § 7-433c payments as special compensation distinct from workers’ compensation)
- Suprenant v. New Britain, 28 Conn. App. 754 (1992) (preemployment exam must show no evidence of hypertension or heart disease to qualify; distinguishable facts)
- Marandino v. Prometheus Pharmacy, 294 Conn. 564 (2010) (Workers’ Compensation Act principles on causation; held inapplicable to § 7-433c here)
- Hernandez v. Gerber Group, 222 Conn. 78 (1992) (causally related injuries treated as one event under Workers’ Compensation Act; inapplicable to § 7-433c)