Duhaime's Law Dictionary


Heart Attack Standard Definition:

A finding or allegation that conditions of employment are so unusual or extraordinary conditions as to have the potential to cause mental disorder or a heart attack.

Related Terms: Heart Attack

A standard developed in United States employment law against which are judicially assessed allegations that a mental injury, such as a mental disorder or a stress-related heart attack, was caused by workplace stress.

In Stokes, the Court:

"... likened mental injury cases to heart attack cases.... [A] heart attack is compensable if it is induced by unexpected strain or overexertion or by unusual or extraordinary conditions of employment.

"[A] heart attack is compensable if it is induced by unexpected strain or overexertion or by unusual or extraordinary conditions of employment.

"[A]n unusual and excessively increased work load (is) an unusual and extraordinary condition of employment making resulting heart attacks accidents compensable under the Workers' Compensation Act."

In Tennant, Justice Toal wrote:

"In order to recover for mental injuries caused solely by emotional stress, or mental-mental injuries, the claimant must show that she was exposed to unusual and extraordinary conditions in her employment and that these unusual and extraordinary conditions were the proximate cause of the mental disorder. This standard, also known as the heart attack standard, balances the employee's interests with the employer's interests and provides a framework which ensures that the claimant shows that she suffered a work-related injury. Requiring a claimant to prove exposure to unusual or extraordinary circumstances in a mental-mental injury claim is consistent with the heightened burden required to prove a claim for intentional infliction of emotional distress claims, a cause of action that also allows recovery for mental injuries in the absence of physical injury ... recognizing that where physical harm is lacking, the courts should look initially for more in the way of extreme outrage as an assurance that the mental disturbance claimed is not fictitious."

REFERENCES:

  • Powell v. Vulcan Materials Co., 384 SE 2d 725 (South Carolina Supreme Court, 1989)
  • Stokes v. First National Bank, 377 SE 2d 922 (South Carolina Court of Appeals, 1988)
  • Tennant v. Beaufort County School District, 674 SE 2d 488 (South Carolina Supreme Court, 2009)

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