In Re Application of Sparling

In In Re Application of Sparling (1983), 36 Ill.Ct.Cl. 353, the court granted an award where a police officer suffered a fatal heart attack while he was off-duty. The evidence established that for most of the year prior to his death Lt. Sparling was in charge of two eight-hour shifts due to a shortage of supervisory personnel. Additionally, two days prior to his death, the deceased was in charge of a strenuous tracking operation that covered several miles in hot and humid weather. Also, on the day before his death, decedent was twice required to lift and carry a fire hydrant weighing 200-300 pounds. The deceased's doctor presented unrefuted testimony that Lt. Sparling suffered from coronary artery disease and the physical exertion of the tracking and the hydrant incidents caused or contributed to his heart attack. Based on the evidence, the Court found that even though the decedent was not on duty at the time of his heart attack the job related exigent circumstances preceding his death were sufficient to constitute a compensable injury within the meaning of the Act. The Court also noted that while the deceased suffered from the underlying coronary artery disease, coverage of this act is not limited to healthy persons. Id. at 356.