Case Law Update September 2026
Village Community Dev. Dist./PGCS v. Illeck, ___So.3d ___ (Fla 1st DCA 9/23/26)
Heart Lung Statute
The firefighter/claimant developed disabling heart conditions of supraventricular tachycardia (SVT) and atrial tachycardia (AT) from an unknown source. The medical opinions agreed the conditions constituted a “heart disease” of the heart’s electrical system, but that the condition did not meet the definition of “heart disease” in the 2023 Harlem case. The JCC ruled for the claimant, in part citing numerous prior DCA cases which found conditions affecting the heart’s electrical system to be heart disease. The DCA rejected the E/C’s argument that Harlem prevented claimant from benefiting from the presumption, finding that Harlem did not exclude arrythmia-based diagnoses of the heart’s electrical system as “heart disease.” Click here to view Opinion