Florida’s heart-lung statute presumes that a firefighter’s heart disease arose from the job — and the First District Court of Appeal held that presumption extends to arrhythmia-based conditions of the heart’s electrical system, not just the “plumbing-related” conditions addressed in its earlier decision in North Collier Fire Control & Rescue District v. Harlem.
Firefighter Chelsea Illeck developed supraventricular tachycardia and atrial tachycardia after suffering cardiac symptoms on the job in the fall of 2023. Both her own and the employer-carrier’s independent medical examiners agreed her condition constituted “heart disease” as the term has been medically understood since Florida enacted the heart-lung statute in 1965 — though both doctors also agreed it did not meet the narrower definition applied in Harlem, which involved arteries, valves and blood pressure rather than the heart’s electrical system. A Judge of Compensation Claims credited that unrebutted medical testimony and awarded benefits under the statutory presumption; the employer-carrier appealed.
The First District affirmed. Harlem, the court explained, addressed only a “cardiac plumbing-related issue” and never purported to cover electrical-system arrhythmias — a category of heart disease its own precedent has recognized for decades. “Because Harlem, however, didn’t address or purport to cover arrythmia-based heart diseases involving the heart’s electrical system, it does not control here,” the panel wrote. With no medical evidence rebutting that Illeck’s condition was heart disease, the presumption applied and the compensation order stood.
Citation: Village Center Community Development District v. Illeck, No. 1D2025-3075 (Fla. 1st DCA Sept. 23, 2026).