Allena Downey worked as an Ashland, Massachusetts police officer from 2002 until September 2013. Beginning in 2012, she experienced frequent premature ventricular contractions (PVCs), or abnormal heartbeats, accompanied by heart palpitations, shortness of breath, dizziness, and chest pain. The PVCs persisted despite medication and, later, surgery. After experiencing severe symptoms while responding to a call in September 2013, Downey stopped working as a police officer and eventually applied for accidental disability retirement (ADR) benefits.
Because Downey had passed a physical examination when she became a police officer, her claim implicated Massachusetts’s “Heart Law.” The statute provides that “any condition of impairment of health caused by hypertension or heart disease” is presumed to have been suffered in the line of duty “unless the contrary be shown by competent evidence.” Thus, the presumption can satisfy the requirement for ADR benefits that an officer’s disabling condition resulted from an injury or hazard suffered in the performance of her duties.
The Middlesex County Retirement System denied Downey’s ADR application. Although a Division of Administrative Law Appeals magistrate reversed that decision, the Contributory Retirement Appeal Board (CRAB) reinstated the denial. CRAB reasoned that Downey’s PVCs were merely a symptom rather than “heart disease.” It further concluded that, even if the statutory presumption applied, evidence that the PVCs were caused by stress and anxiety from home life, medication, alcohol, and opiates rebutted it. The Superior Court affirmed CRAB. Downey appealed.
The Massachusetts Appeals Court rejected CRAB’s approach and reversed. The Court explained that the Heart Law does not define “heart disease,” and Massachusetts precedent favors a broad application of its presumption. Given the heart’s complex functions and pathologies, the Court concluded that it could not “exclude persistent PVCs that have proven resistant to treatment from the broad reach of the phrase ‘heart disease.’”
More importantly, the Court held that CRAB had applied the presumption backward. To receive the benefit of the Heart Law, Downey had to establish the existence of heart disease, not identify what caused that disease. The undisputed evidence that her heart experienced persistent, treatment-resistant PVCs was sufficient to invoke the presumption. Requiring Downey to additionally prove the PVCs’ underlying cause would defeat the statute’s purpose of presuming that the condition arose in the line of duty “without the need to prove further any such causal connection.”
Once the presumption applied, the burden was instead on the other side to produce “competent evidence” showing that the PVCs were not suffered in the line of duty. CRAB therefore erred by treating Downey’s inability to identify the cause of her PVCs as a reason to deny her the presumption and by analyzing possible non-work causes under that mistaken premise. The Appeals Court reversed the Superior Court’s judgment and ordered the case remanded to CRAB to reconsider Downey’s claim under the proper application of the Heart Law presumption.
Downey v. Contributory Retirement Appeal Board, No. 25-P-244, 2026 WL 2435130 (Mass. App. Ct. Aug. 20, 2026).