HEART ATTACK
Emotional stress
The principles of Sutherland (4 Wn. App. 333) apply to a claim for a heart attack precipitated by unusual emotional stress whether the stress is caused by an external, tangible and objective event which has taken place or one which is about to take place. ....James Hammond, 67,968 (1986)
Presumption in RCW 51.32.185
If the facts support a finding that the presumption in RCW 51.32.185 applies, findings and conclusions regarding the presumption are required. ….Steve Goforth, 09 16328 (2010)
A firefighter must initially offer evidence that the condition is one contemplated by the statute. Only after doing so is the burden shifted to the Department or the self‑insured employer to rebut the presumption by a preponderance of the evidence. ….Edward Gorre, 09 13340 (2010)
[Editor's Note: The Board's decision was appealed to superior court under Pierce County Cause No. 11-2-05064-1.]
Unusual exertion
The duties of a job at a cement plant were not routine for a worker who, immediately prior to the injury, had been retired for six to seven years in a sedentary lifestyle. The physical exertion of the job was "unusual" even though the worker had been employed in the same job prior to retirement. ....Harley Buchner, Dec'd., 59,239 (1982) [dissent] [Editor's Note: The Board's decision was appealed to superior court under Whatcom County Cause No. 82-2-00922-5.]