Matter of Ernest Jr. v. Boggs Lake Estates, Inc., 39 N.Y.2d 91 (1976)

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Under New York’s Workmen’s Compensation Law, a heart attack suffered by an employee can be considered an accidental injury if the physical effort involved, even if not strenuous for a healthy person, was too strenuous for the employee’s pre-existing condition, and there is sufficient medical evidence linking the work to the death.

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Summary

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The New York Court of Appeals reversed the Appellate Division’s decision and reinstated the Workers’ Compensation Board’s award to the claimant. The court found that the decedent’s death from a heart attack, triggered by helping carry heavy luggage, constituted an accidental injury within the meaning of the Workmen’s Compensation Law. Even though the task might not be strenuous for an average person, the court emphasized that it was strenuous for the decedent, given his pre-existing cardiac condition, and that competent medical opinion supported the causal link between the exertion and his death. This ruling reinforces the principle that the