## Facts

- Alcide Guidry, a 53-year-old industrial painter employed by Sline Industrial Painters, Inc., worked a full morning and early afternoon using and repeatedly moving/bracing a 10–12-foot ladder.
- He took brief breaks around 10:00 a.m. and at noon.
- Around 2:00 p.m., during a short smoke break, Guidry collapsed at the jobsite and died from an acute myocardial infarction secondary to atherosclerotic heart disease.
- Two family physicians testified the heart attack was unrelated to Guidry’s work and would have occurred regardless of activity due to underlying coronary disease.
- A cardiologist testified the sustained physical exertion at work could have contributed to precipitating the infarction, but framed the connection as medically possible.
- Guidry’s widow sought workers’ compensation death benefits, alleging that work-related exertion caused or contributed to the heart attack.

## Issues

1. Whether a heart attack occurring at work is compensable only if job-related stress, strain, or exertion caused, contributed to, or aggravated the condition precipitating the infarction.
2. Whether the claimant proved by a preponderance of the evidence that Guidry’s work activities probably contributed to his fatal heart attack, given conflicting medical testimony and evidence that the work was routine.

## Decision

- The Louisiana Supreme Court reversed the court of appeal and reinstated the trial court’s judgment denying benefits.
- The court held that compensability requires proof of a causal relationship between employment stress/strain/exertion and the heart attack.
- The claimant failed to prove it was more likely than not that work-related exertion contributed to, aggravated, or accelerated the heart malfunction.
- The court treated the cardiologist’s opinion as too equivocal when weighed against the more definitive testimony of the two family physicians.
- The court concluded the ladder work was routine for the job and was not shown to involve sudden or extraordinary strain sufficient to support an inference of causation.
- The court emphasized deference to the trial court’s credibility choices and factual findings in resolving conflicting medical evidence absent manifest error.

## Legal Principles

- A myocardial infarction may qualify as an “accident” under workers’ compensation if it occurs unexpectedly, but compensability additionally requires a work-related causal contribution.
- Temporal coincidence alone (the heart attack occurring while at work) does not establish compensability.
- The claimant must prove by a preponderance of the evidence that employment stress, strain, exertion, or comparable work-related stress contributed to, aggravated, or accelerated the heart condition so as to precipitate the infarction.
- Medical testimony stating only that work “could have” contributed, without establishing probability, generally does not satisfy the claimant’s burden when countered by stronger evidence of non-work-related causation.
- Appellate courts should not reweigh conflicting evidence where the trial court’s causation findings are reasonably supported and not manifestly erroneous.

## Conclusion

The court denied workers’ compensation death benefits because the claimant did not prove that routine work exertion probably contributed to or aggravated the underlying heart disease to precipitate the fatal heart attack, and the trial court’s rejection of causation was entitled to appellate deference.


Guidry v. Sline Indus. Painters, Inc., 418 So. 2d 626 (La. 1982)