The basis for granting and denial of compensation for heart attacks in the several states runs the gamut from common-sense reasoning to arbitrary adherence to rigid construction of the compensation statutes. To add to the difficulty as to the compensability of a heart attack injury, the courts must first resolve the question as to whether or not the injury or death was incurred in the course of employment. This issue in and of itself ofttimes poses questions that are sufficient to tax even the most adept legal minds. In cases involving heart attacks the courts are additionally burdened by having to decide whether or not the heart attack, which did occur in the course of employment, was job-connected as opposed to a natural occurrence independent of the employment.
Richard W. Dunn, Workmen's Compensation and Heart Attacks, 11 Clev.-Marshall L. Rev. 210 (1962)