Firefighter’s AFib fight rewrites Florida’s definition of heart disease

The court went back to 1965, when the legislature wrote the statute without defining “heart disease.” A 1957 medical dictionary defined it as “any organic, mechanical, or functional condition of the heart that causes trouble.” The World Health Organization classified auricular fibrillation under functional heart disease that same year. The term had always covered conditions disrupting how the heart works – not just those damaging its structure. 

The court found Harlem had been stretched too far. That case involved an aneurysm in the thoracic aorta – a bulge in a large artery leading from the heart. Different organ, different question. A September 2026 decision in Illeck confirmed the point: Harlem’s was a “limited-purpose definition” never meant to shut the door on electrical heart conditions. 

With every other requirement uncontested, the court held the firefighter’s AFib was covered. The case goes back for remaining benefit issues. A separate denial involving hypertension, which he did not challenge, stays in place. 

For HR teams handling first-responder comp in Florida, the takeaway is direct: functional heart conditions like AFib sit within the heart-lung presumption. 

The decision is not yet final pending any timely motions under Florida’s appellate rules.