Florida Court Counts Atrial Fibrillation as Heart Disease
Firefighters with irregular heartbeats may now qualify for coverage under the state's heart-lung presumption law.
Updated on Nov. 6, 2026 in Heart Disease
Live Poll
Should first responders with heart conditions be presumed to have gotten them on the job?
Florida's First District Court of Appeal set aside a workers' compensation denial for a St. Johns County firefighter's atrial fibrillation claim on November 4, 2026. The court held that atrial fibrillation qualifies as heart disease under the state's heart-lung presumption statute, which covers firefighters.
Why it matters
Firefighters in Florida who develop heart rhythm disorders may now have a clearer path to coverage under the state's heart-lung presumption law. The ruling narrows how a prior court decision had been applied, so the scope of the definition of heart disease is now clarified for similar claims.
The ruling rests on testimony from two independent cardiologists who described atrial fibrillation as an electrical disorder, and who found no structural damage, weakened vessels, or degraded valves. The appellate court's review centered on statutory interpretation rather than new clinical data.
The players
First District Court of Appeal
Florida's intermediate appellate court, which reviews state trial-level rulings including workers' compensation decisions.
St. Johns County Fire Rescue
The St. Johns County, Florida agency that employed the firefighter, whose emergency medical and fire services cover the county.
Preferred Governmental Claims Solutions
The workers' compensation carrier that handled the claim on behalf of the employer.
The details
The compensation judge had read heart disease as limited to conditions that physically weaken the heart, and relied on the 2009 case North Collier Fire Control and Rescue District v. Harlem to deny the claim. The appellate court went back to the 1965 legislative enactment and found Harlem had been stretched too far, since that case involved a thoracic aorta aneurysm, a different organ and question. A September 2026 decision in Illeck described Harlem's definition as limited in purpose and not meant to exclude electrical heart conditions.
Timeline
1957: a medical dictionary defined heart disease to include functional conditions of the heart.
1965: the Florida Legislature enacted the heart-lung statute without defining heart disease.
2007: the firefighter began service with St. Johns County Fire Rescue.
August 24, 2023: the firefighter experienced palpitations and was diagnosed with atrial fibrillation.
November 4, 2026: the First District Court of Appeal set aside the denial.
Health Landscape
The decision reads the heart-lung presumption statute by its 1965 text rather than by a narrower later precedent, placing atrial fibrillation within the protected category of heart disease. It shows how state courts can shape which common cardiac conditions qualify for occupational protections for first responders.
If you work in firefighting or another first-responder role and have been diagnosed with an irregular heartbeat, it is worth asking your physician to document your cardiac history and any pre-employment screening results. Anyone with palpitations or a rapid, irregular pulse should discuss those symptoms with a clinician promptly.
The takeaway
Atrial fibrillation is an electrical rhythm disorder, and this ruling affirms that such conditions can count as heart disease under Florida law. Anyone who notices heart palpitations or an irregular pulse should raise it with a physician, and first responders should keep records of their cardiac screenings.
Further reading
For more on the conditions behind this ruling, explore our Heart Disease coverage.
Source note: This article includes information reported by Human Resources Director.
Live Poll
Should first responders with heart conditions be presumed to have gotten them on the job?
