Mandelblatt v. Meilman, 29 N.Y.2d 20 (1971)

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For a heart injury to be compensable under Workmen’s Compensation Law, the work performed must be strenuous for the individual, given their pre-existing condition, and there must be medical evidence causally connecting the work to the cardiac event.

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Summary

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Mandelblatt, the claimant’s deceased husband, suffered a fatal cardiac event shortly after working as a bus driver on a particularly hot day. The Workmen’s Compensation Board ruled in favor of the claimant, finding a causal link between the strenuous work and the death. The Appellate Division reversed. The New York Court of Appeals reversed the Appellate Division. The court emphasized that what constitutes “strenuous work” is subjective and depends on the individual’s physical condition. The court found sufficient evidence that the work was strenuous for the decedent, given his impaired cardiac ability, and that medical testimony supported the causal connection between the work and his death.

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Facts

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The decedent, a bus driver, had a history of heart problems, including previous heart attacks, which impaired his cardiac ability. On July 17, 1964, he worked driving a bus on a day when the temperature reached 87 degrees. The route involved 20 turns, and the road was described as