Court: New Jersey Superior Court Appellate Division; October 29, 1985; New Jersey; State Appellate Court
The court, represented by Judge King, upheld a judgment awarding total and permanent disability to the petitioner, who claimed a cardiovascular injury resulted from his work efforts. The respondent, Ocean County, argued that the petitioner failed to prove that his work-related activities constituted a substantial strain beyond daily living, as required by N.J.S.A. 34:15-7.2 and related legislation from the 1980 reform act. This legislation aimed to increase compensation for serious injuries while making it harder to claim lesser injuries.
The petitioner, age 62, had a long tenure with Ocean County, primarily as a laborer and equipment operator. On February 10, 1982, after a night shift of sanding icy roads, he engaged in heavy shoveling of a coal patch, which he described as exhausting, particularly due to the cold weather. He reported experiencing numbness and chest pain during this task, leading to a cardiac episode that necessitated triple bypass surgery.
The key evidence supporting the petitioner's claim came from Dr. Melvin C. White, a cardiologist, who testified that the work effort exceeded normal daily activities and materially contributed to the petitioner’s cardiac injury. The court found sufficient evidence to affirm the compensation judge’s decision, despite contested facts and medical interpretations presented by the respondent.
Dr. White opined that Mr. Arsi's extended work activities significantly worsened his cardiac condition. He elaborated on the relationship between the heart's demand for blood and the supply limitations posed by blockages in the coronary arteries. Specifically, excessive physical exertion, such as heavy lifting and shoveling, increased Mr. Arsi's blood pressure and oxygen demand, while cold weather caused blood vessel constriction, compounding the strain on his heart. These factors led to angina pectoris, or chest pain. Dr. White identified the strenuous work, harsh weather, and resultant fatigue from a double shift as key contributors to Mr. Arsi's condition, concluding that he was "totally and permanently disabled" as of February 1984.
During cross-examination, Dr. White acknowledged Mr. Arsi’s existing coronary arteriosclerosis but maintained that the work activities exacerbated this condition, leading to angina. He indicated that the physical demands placed on Mr. Arsi during that day were critical in provoking his symptoms. Dr. Roland Goodman, an internal medicine specialist, supported this view, asserting that the labor performed on February 10, 1982, in cold weather after minimal rest resulted in physiological changes in Mr. Arsi's heart. He noted that the body's natural response to cold, which involves constricting blood vessels for warmth, further increased the heart's workload, creating a mismatch between demand and the heart's ability to supply blood due to pre-existing damage from a previous heart attack.
A patient developed chest pains and collapsed, ultimately diagnosed with three-vessel coronary artery disease requiring coronary artery bypass surgery. Post-surgery, he experienced an inferior wall myocardial infarction, leading to significant heart muscle damage, diminished pumping ability, and fluid accumulation in the lungs, which was noted through stethoscope examination revealing moist basal rales. There was anatomical disorganization of the heart, including a murmur and narrowed aortic valve, contributing to heart muscle weakness. Despite surgery, the patient's angina persisted, requiring medications such as Nitrobid, Persantine, and Isordil. He was unable to work, experiencing fatigue, chest pain, and shortness of breath. A medical expert concluded that the physical strain and effort on February 10, 1982, were significant in exacerbating his cardiac condition, transforming his prior asymptomatic state into one of severe angina necessitating surgery. In contrast, a defense cardiologist argued that the February 10 event was unrelated to the patient’s current condition and merely a transient episode of angina. The resolution of these conflicting medical opinions was left to the judge of compensation, who ultimately found that the patient had established a case for total and permanent disability. Testimonies confirmed that the patient had worked a full day before being called in for emergency work due to bad weather, during which he experienced severe chest pains after physically exerting himself under stressful conditions.
The strain experienced by the petitioner prior to February 10, 1982, exceeded typical daily wear and tear, despite a history of mild angina-like pain and a prior hospitalization for a suspected heart attack in 1974, which had no recurrence for eight years. There was no evidence of work loss or medical restrictions due to cardiac issues before the specified date. The timing of the strenuous work effort and the onset of severe cardiac symptoms supports Dr. Goodman’s opinion that the sudden demand on the heart caused significant narrowing of the coronary arteries. Testimonies from Dr. Goodman and Dr. Issacson indicate the petitioner had arteriosclerosis and mild angina, both of which were exacerbated by his work effort, leading to unstable angina that required bypass surgery. It is concluded that the work effort directly caused the petitioner’s condition. The statutory requirements for compensation under N.J.S.A. 34:15-7.2 were met, as the injury arose from a substantial work-related strain beyond normal wear and tear. The petitioner was working a double shift in cold weather with limited sleep and was engaged in strenuous physical activity beyond his usual duties. The validity of hypothetical questions posed to medical experts was questioned but did not warrant a new trial, as the judge accurately understood and analyzed the evidence despite discrepancies in the hypothetical scenarios. Affirmation of the decision is warranted based on the evidence presented.