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Estate of Sullwold v. The Salvation Army

Maine Supreme Judicial Court
108 A.3d 1265 (2015)


Facts

Gregory Sullwold lived in Maine and worked remotely as a portfolio specialist and comptroller for the Salvation Army (defendant). The Salvation Army supplied Sullwold with a BlackBerry and other materials for his home office. On February 23, 2010, Sullwold began working in his home office at 8:30 am and continued working until 3:30 pm. He then took a break to walk on his home treadmill but kept his BlackBerry with him. While he was on the treadmill, Sullwold suffered a heart attack and died. Sullwold had been receiving treatment for heart disease since a previous heart attack in 1993. Sullwold’s wife and coworkers described him as being under stress from his work due to long hours, frequent travel, and the effect of the economic recession on the Salvation Army’s finances. Sullwold had also suffered a panic attack shortly before his death, which he said was caused by “overload.” In 2011, Sullwold’s estate (plaintiff) petitioned the Maine Workers’ Compensation Board for an award of workers’-compensation benefits, asserting that Sullwold’s work resulted in a heart attack and cardiac arrest. The board granted the petition, and a hearing officer reaffirmed the decision. The Maine Appellate Division affirmed the award, and The Salvation Army appealed to the Maine Supreme Judicial Court.

Rule of Law

Issue

Holding and Reasoning (Hjelm, J.)

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