## Facts

- Patrick J. Griffin worked on oven construction/repair jobs that could involve heavy lifting; some other assignments were lighter.
- Griffin had severe preexisting heart disease, including arteriosclerosis and hypertension, and had recently been advised by a physician to rest and avoid laborious work.
- On July 22, 1940, Griffin was assigned with a crew to set up a baker’s oven at a bakery and spent about forty-five minutes unloading and carrying construction materials from a truck into the premises.
- Around 11 a.m., Griffin collapsed and died of acute heart failure while performing that work.
- Medical experts conflicted on causation: the insurer’s physician opined the work did not contribute to death; two physicians for the widow testified that the exertion strained and overtaxed Griffin’s diseased heart and directly contributed to the fatal heart failure.
- A single member of the Industrial Accident Board credited the widow’s medical testimony, found the exertion contributed to death, and awarded death benefits; the full Board adopted those findings.
- The Superior Court entered a decree consistent with the Board’s decision; the insurer appealed.

## Issues

1. Whether an employee’s death from acute heart failure while performing heavy lifting constituted a compensable personal injury arising out of and in the course of employment when the employee had serious preexisting heart disease.
2. Whether the evidence warranted the Industrial Accident Board’s findings on medical causation and supported the decree awarding compensation.

## Decision

- The Supreme Judicial Court affirmed the Superior Court decree awarding workers’ compensation death benefits.
- The court held it was undisputed that the death occurred “in the course of” employment.
- The court further held the evidence warranted the Board’s finding that the work-related exertion was a proximate cause of death, satisfying the “arising out of” requirement.
- The court accepted the Board’s resolution of conflicting expert testimony in favor of the widow’s experts as a permissible fact-finding choice supported by the record.

## Legal Principles

- Under the Massachusetts Workmen’s Compensation Act, a death may “arise out of” employment when work exertion is a proximate contributing cause of a fatal medical event.
- A serious preexisting disease does not bar compensation if employment-related exertion aggravates, accelerates, or contributes to disability or death.
- In reviewing workers’ compensation awards, appellate courts ask whether the evidence warrants the Board’s findings and whether those findings support the decree; conflicts in medical testimony are for the Board to resolve.
- Heavy lifting and similar strenuous work can constitute legally sufficient exertion even if it is routine for the employee’s job.

## Conclusion

Compensation was properly awarded because the Industrial Accident Board could find, on credited medical testimony and the circumstances of the collapse, that Griffin’s heavy lifting at work proximately contributed to his acute heart failure and thus his death arose out of and in the course of employment despite his preexisting heart disease.


Griffin's Case, 315 Mass. 71, 51 N.E.2d 768 (Mass. 1943)