## Facts

- Richard Lindquist worked as a full-time Jersey City firefighter from 1972 to 1995, retiring as a captain.
- He responded to frequent fires, including many large fires during his early years, and described repeated exposure to heavy smoke and fumes, sometimes for extended periods.
- Respiratory protection existed but was not consistently used early in his career; later-issued masks reduced but did not eliminate inhalation of smoke and fumes, and he sometimes removed the mask to communicate or clear moisture.
- Fires involved ordinary combustibles and materials such as plastics, chemicals, household cleaners, and propane, creating exposure to toxic combustion by-products.
- Lindquist had a cigarette-smoking history (about three-quarters of a pack per day for roughly twenty-two years).
- His medical expert diagnosed COPD in the form of emphysema and opined that occupational firefighting exposures were a primary cause, without assigning a numerical apportionment between smoking and workplace exposure.
- A Judge of Compensation found Lindquist’s occupational exposure materially contributed to his emphysema and awarded benefits for 30% disability; the Appellate Division reversed for insufficient proof of medical causation.

## Issues

1. Whether an occupational disease claim is proven when workplace exposure materially contributes to emphysema, even if the employee also has a substantial non-occupational risk factor (cigarette smoking).
2. Whether medical causation requires precise percentage apportionment between occupational and non-occupational causes.
3. What level of deference an appellate court owes to a Judge of Compensation’s fact findings and credibility determinations on causation.

## Decision

- The Supreme Court of New Jersey reversed the Appellate Division and reinstated the Judge of Compensation’s award.
- The Court held there was sufficient credible evidence that firefighting exposures materially contributed to Lindquist’s emphysema.
- The Court rejected a requirement of epidemiological certainty or precise apportionment between smoking and occupational exposure.
- The Court emphasized that the Appellate Division improperly reweighed evidence and substituted its judgment for the compensation judge’s supported factual findings.

## Legal Principles

- An occupational disease is compensable when workplace exposure materially or substantially contributes to the development or aggravation of the condition; employment need not be the sole or predominant cause.
- The Workers’ Compensation Act is construed liberally in favor of coverage, and causation may be established without scientific certainty.
- The presence of non-occupational risk factors (including smoking) does not bar compensation if work exposure materially contributes.
- Expert testimony need not assign precise percentages of causation to satisfy the material-contribution standard.
- Appellate courts must defer to a Judge of Compensation’s factual findings, including credibility assessments and weighing of expert testimony, when supported by sufficient credible evidence; legal interpretations receive no special deference.

## Conclusion

The court held that Lindquist established compensable occupational disease because credible evidence supported that long-term firefighting exposures materially contributed to his emphysema, and it restored the compensation award despite his smoking history and the absence of precise causal apportionment.


Lindquist v. City of Jersey City Fire Dep’t, 175 N.J. 244, 814 A.2d 1069 (2003)