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Administrators with high blood pressure denied protection for secondary diagnosis



An occupational injury claim filed by a law enforcement agency with a history of high blood pressure was denied compensation, a Florida Court of Appeal ruled Wednesday.

As a teenager, Joshua Holcombe underwent a liver transplant that required him to take medication for rejection. over the next 15 years. Mr. Holcombe developed secondary hypertension as a side effect of the medication, which later disappeared after treatment was discontinued. He was employed as a law enforcement officer by the city of Naples several years later, and in the following years he was diagnosed with essential hypertension, according to documents in Joshua Holcombe v. City of Naples, filed with the District Court of Appeal of Florida, First District, Tallahassee.

Upon employment, Holcombe underwent a pre-employment physical examination that required him to complete a self-report medical history questionnaire. He answered "yes" to a question about the history of high blood pressure. As part of the physical examination, the examiner reviewed a note from his primary care physician that his high blood pressure had returned to normal when the medication was discontinued, documents state.

When Holcombe was diagnosed with essential hypertension several years after his service, he filed a workers' compensation claim. He was denied compensation on the presumption that the pre-employment physical examination contained documented evidence of high blood pressure.

He filed a claim for benefits in which he sought compensation for "arterial and cardiovascular hypertension", and was again denied compensation by the judge for claims for the same reason that evidence of pre-existing hypertension precludes his reliance on the presumption.

On appeal, the Court agreed that evidence of secondary hypertension on Holcombe's PEP precludes his use of the presumption of occupational cause of essential hypertension, and upheld the JCC judgment.

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