City & County of San Francisco v. Workers' Compensation Appeals Board

583 P.2d 151, 22 Cal. 3d 103, 148 Cal. Rptr. 626, 43 Cal. Comp. Cases 984, 1978 Cal. LEXIS 278
CourtCalifornia Supreme Court
DecidedSeptember 13, 1978
DocketS.F. 23338
StatusPublished
Cited by33 cases

This text of 583 P.2d 151 (City & County of San Francisco v. Workers' Compensation Appeals Board) is published on Counsel Stack Legal Research, covering California Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
City & County of San Francisco v. Workers' Compensation Appeals Board, 583 P.2d 151, 22 Cal. 3d 103, 148 Cal. Rptr. 626, 43 Cal. Comp. Cases 984, 1978 Cal. LEXIS 278 (Cal. 1978).

Opinions

Opinion

TOBRINER, J.

For nearly forty years, Labor Code section 3212.5 has provided that when a police officer who has been employed for five or more years develops “heart trouble,” the condition is presumed, subject to rebuttal, to have arisen out of and in the course of his employment and thus to be compensable under the workers’ compensation law. In 1959, the Legislature amended the section to provide that an employer may not rebut section 3212.5’s presumption, and thus may not defeat an ailing police officer’s workers’ compensation claim, on the basis of evidence attributing the officer’s heart trouble to a preexisting heart disease.1 Although the 1959 amendment has been applied regularly by both the Workers Compensation Appeals Board (WCAB) and the California courts for almost two decades, in the instant case the City and County of San Francisco (hereafter employer) contends that this portion of the statute is invalid under distinct provisions of both the California and the [107]*107United States Constitutions. As we explain, we find no merit in the employer’s constitutional contentions and accordingly we affirm the WCAB award.

1. The facts

Leonard F. Wiebe joined the San Francisco Police Department on July 13, 1943, and served on the police force for more than 25 years, retiring on November 16, 1968. On September 3, 1972, Wiebe collapsed while shopping and died shortly thereafter, the victim of a massive heart attack. The city acknowledges that Wiebe’s heart attack “developed and manifested itself’ within five years of his retirement and concedes that, if section 3212.5 is constitutional, the officer’s wife and child are entitled to invoke the benefits afforded by that provision. (See fn. 1, ante.)

Following Wiebe’s death, his wife and daughter filed a workers’ compensation application for death benefits and burial expenses. The employer contested the claim, arguing that Wiebe’s heart attack was not in any way related to his lengthy employment with the city police department. In support of this contention, the employer offered a medical report and testimony of Dr. Frederic Mintz, a cardiovascular specialist employed by the city as an expert witness.

Although Dr. Mintz apparently had no knowledge of, and made no inquiry into, the details of the decedent’s 25 years of police employment, Dr. Mintz concluded, after reviewing the decedent’s medical records, that “I cannot ... on medical grounds reasonably relate his coronary heart disease and myocardial infarction to his employment as a police officer—” Dr. Mintz’s report reveals that his conclusion was not based on any peculiarity of Wiebe’s heart attack, but rather rested on the doctor’s general academic medical opinion that job stress and exertion do not play a causal role in the development or progression of coronary heart disease.2 On the basis of Dr. Mintz’s opinion, the employer contended that the WCAB should deny the claimed workers’ compensation benefits.

[108]*108The Wiebes, apparently satisfied that section 3212.5’s statutoiy presumption of work-relatedness had not been rebutted, presented no contrary medical evidence on their behalf, and the WCAB, rejecting the employer’s constitutional attack on section 3212.5, concluded that under that section Dr. Mintz’s testimony was insufficient to defeat the Wiebes’ workers’ compensation claim. Accordingly, the WCAB awarded the Wiebes the statutorily authorized death benefit and burial expenses.

The employer now seeks annulment of the WCAB award, contending that the 1959 amendment to section 3212.5, upon which the WCAB relied, is unconstitutional in two respects. First, the employer argues that in adopting the 1959 amendment, the Legislature exceeded the constitutional authority to enact workers’ compensation legislation afforded by article XIV section 4 of the California Constitution. Second, the employer maintains that, in any event, the 1959 amendment constitutes an impermissible conclusive presumption violative of federal due process guarantees. After setting forth the legislative history and purpose of the challenged statutoiy provision, we discuss each of the employer’s contentions in turn.

2. The legislative history and purpose of the 1959 amendment to section 3212.5.

To analyze properly the city’s constitutional claims, we must at the outset place the 1959 amendment to section 3212.5 in context by identifying the serious problem at which the legislation was directed. That problem, widely recognized in both the legal literature and the case law as “probably the most prolific and troublesome problem in workmen’s compensation law” (Larson, The “Heart Cases” in Workmen’s Compensation: An Analysis and Suggested Solution (1967) 65 Mich.L.Rev. 441, 441), arises from “the persisting cleavage in medical theory itself’ [109]*109(id, at p. 475) as to the relationship between stress, physical exertion and progressive heart disease.3

Some doctors, like Dr. Mintz, who testified on behalf of the employer in the instant case, hold to the view that emotional stress and physical exertion normally do not contribute in any way to the development or progression of coronary arteriosclerosis and accordingly believe that heart attacks resulting from such progressive heart disease generally bear no relation to employment activities, even when such employment entails considerable stress or exertion. Many medical experts, however, subscribe to the contrary view that emotional stress and physical exertion do contribute to and aggravate the development and progression of arteriosclerosis, and these physicians consequently believe that employment conditions which subject an individual to considerable stress and physical exertion do hasten the development of such heart disease and thus are contributing causative factors in any ultimate heart attack that results from the progression of such preexisting heart disease.

For many years, this split in medical opinion upon one of the most comnitirily litigated issues in workers’ compensation matters has seriously undermined the efficacy, consistency and basic fairness of the WCAB’s normal case-by-case determination of the work-relatedness of an employee’s injury or illness. As one commentator has pointed out, “the overwhelming majority of the cases in this area involve conflicts in medical testimony, and it is not unusual to see one doctor appearing frequently on the side of employers while another doctor is often visible as a plaintiff’s expert. Regardless of the factual setting, the employer’s doctor invariably determines that the death or injury is entirely due to the pre-existing disease and is not work-related while the plaintiff’s expert continuously finds the problem to have been precipitated by stress of the job. Since the ultimate decision as to whether or not the employment contributed to the harm is a question of fact for the determination of the Appeals Board, and the testimony of any single doctor is generally sufficient to sustain the findings of the Board, the result in a particular [110]*110case cannot be anticipated.” (Italics added, fns. omitted.) (Note, A Problem of Proof, supra, 2 Pacific L.J. 678, 689-690.)

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Bluebook (online)
583 P.2d 151, 22 Cal. 3d 103, 148 Cal. Rptr. 626, 43 Cal. Comp. Cases 984, 1978 Cal. LEXIS 278, Counsel Stack Legal Research, https://law.counselstack.com/opinion/city-county-of-san-francisco-v-workers-compensation-appeals-board-cal-1978.