## Facts

- The decedent (age 33) worked as director of maintenance and engineering for an airline.
- Eight months before his death, he passed a physical exam for a pilot’s license showing an “essentially normal” condition and had no known cardiac history.
- After one of the employer’s planes was grounded for wing corrosion, the company president publicly blamed the decedent for “sheer negligence,” criticized him at a company gathering, and threatened job loss if the aircraft was not returned to service by a deadline.
- The decedent made repeated work trips to supervise repairs, sought replacement parts across states, and faced continuing pressure to return the aircraft to service.
- In early March 1956, while in Brownsville, Texas, the decedent learned the aircraft was not close to ready and was presented with a substantial repair bill.
- Evidence before the Workers’ Compensation Board showed the decedent was in a severe, prolonged emotional upset during the three days before his death.
- On March 10, 1956, the decedent died in Brownsville from a myocardial infarction.
- Medical testimony, including an impartial specialist appointed by the Board, attributed the infarction to prolonged and intense work-related worry and anxiety.
- The Workers’ Compensation Board awarded death benefits; the Appellate Division reversed and dismissed; the widow appealed.

## Issues

1. Whether substantial evidence supported the Workers’ Compensation Board’s finding that severe, prolonged work-related emotional stress caused or precipitated the decedent’s fatal myocardial infarction.
2. Whether an appellate court may overturn the Board’s causation determination where competent medical testimony supports it, despite the absence of unusual physical exertion.

## Decision

- The Court of Appeals reversed the Appellate Division and reinstated the Workers’ Compensation Board’s award of death benefits.
- The court held that substantial evidence supported the Board’s finding of causal relationship between the decedent’s work-related emotional stress and the fatal myocardial infarction.
- The court concluded the Appellate Division improperly substituted its judgment for the Board’s fact-finding on causation.

## Legal Principles

- In workers’ compensation cases, the Board’s determination on causation must be upheld if supported by substantial evidence, including competent medical testimony.
- A myocardial infarction may be compensable when medical evidence shows it was precipitated by severe, prolonged work-related emotional stress, even without unusual physical exertion.
- Temporal proximity between peak work-related emotional stress and the cardiovascular event, combined with evidence of prior good health, may support a causation inference.
- Appellate review is limited; disagreement with the Board’s weighing of medical proof does not justify reversal when the record contains substantial supporting evidence.

## Conclusion

The court reinstated death benefits because competent medical proof and the surrounding work circumstances provided substantial evidence that sustained, intense job-related emotional stress precipitated the decedent’s fatal heart attack, and appellate courts must defer to the Board’s supported causation findings.


Matter of Klimas v. Trans Caribbean Airways, Inc., 10 N.Y.2d 209 (N.Y. 1961)