Connecticut General Statutes

Conn. Gen. Stat. § 7-433c (2026)

Benefits for policemen or firemen disabled or dead as a result of hypertension or heart disease

✓ current as of May 2026
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(a) Notwithstanding any provision of chapter 568 or any other general statute, charter, special act or ordinance to the contrary, in the event a uniformed member of a paid municipal fire department or a regular member of a paid municipal police department who successfully passed a physical examination on entry into such service, which examination failed to reveal any evidence of hypertension or heart disease, suffers either off duty or on duty any condition or impairment of health caused by hypertension or heart disease resulting in his death or his temporary or permanent, total or partial disability, he or his dependents, as the case may be, shall receive from his municipal employer compensation and medical care in the same amount and the same manner as that provided under chapter 568 if such death or disability was caused by a personal injury which arose out of and in the course of his employment and was suffered in the line of duty and within the scope of his employment, and from the municipal or state retirement system under which he is covered, he or his dependents, as the case may be, shall receive the same retirement or survivor benefits which would be paid under said system if such death or disability was caused by a personal injury which arose out of and in the course of his employment, and was suffered in the line of duty and within the scope of his employment. If successful passage of such a physical examination was, at the time of his employment, required as a condition for such employment, no proof or record of such examination shall be required as evidence in the maintenance of a claim under this section or under such municipal or state retirement systems. The benefits provided by this section shall be in lieu of any other benefits which such policeman or fireman or his dependents may be entitled to receive from his municipal employer under the provisions of chapter 568 or the municipal or state retirement system under which he is covered, except as provided by this section, as a result of any condition or impairment of health caused by hypertension or heart disease resulting in his death or his temporary or permanent, total or partial disability. As used in this section, “municipal employer” has the same meaning as provided in section 7-467.

(b) Notwithstanding the provisions of subsection (a) of this section, those persons who began employment on or after July 1, 1996, shall not be eligible for any benefits pursuant to this section.

(1971, P.A. 524, S. 1; P.A. 77-520, S. 1, 3; P.A. 92-81, S. 1, 3; P.A. 96-230, S. 2, 3; 96-231, S. 1, 2; P.A. 14-122, S. 72.)

History: P.A. 77-520 provided that benefits under section be in lieu of others except as specified; P.A. 92-81 added Subsec. (b) re benefits for police officers and firefighters who begin employment on or after July 1, 1992; P.A. 96-230 amended Subsec. (b) to read “Notwithstanding the provisions of subsection (a) of this section, those persons who began employment on or after the effective date of this act (July 1, 1996) shall not be eligible for any benefits pursuant to this section.”, effective July 1, 1996; P.A. 96-231 deleted legislative finding from Subsec. (a) and amended Subsec. (b) to read “Notwithstanding the provisions of subsection (a) of this section, only those persons employed on the effective date of this act (July 1, 1996) shall be eligible for any benefits provided by this section.”, effective July 1, 1996 (Revisor's note: Pursuant to the provisions of Sec. 2-30b the amendment to Subsec. (b) of this section contained in P.A. 96-231 did not take effect since it was deemed repealed by the conflicting amendment to said Subsec. (b) contained in P.A. 96-230 which passed the General Assembly later than P.A. 96-231); P.A. 14-122 made technical changes in Subsec. (a).

Only procedure mentioned for bringing claims under section is the Workmen's Compensation Act. 165 C. 615. Statute serves a public purpose and is constitutional despite its conferring a direct benefit on a certain class of individuals. 168 C. 84. Cited. 177 C. 456. Statute is neither a workers' compensation law nor occupational disease law within meaning of insurance contract. 178 C. 664. Workers' compensation statutes are not the exclusive remedy for injuries arising out of and in the course of employment where injuries claimed are compensable under this statute. 193 C. 59. Benefits under statute may be taken into account in determining maximum amount payable from pension plan; history and interpretation discussed. 194 C. 139. Purpose not to remove benefits from realm of arm's-length collective bargaining but merely to ensure that they are provided for members of police and fire departments. 201 C. 577. Cited. 204 C. 563; 207 C. 665. Does not require payment of benefits to estate of a deceased recipient. 208 C. 576. Use of words “hypertensive” and “heart disease” on claim form sufficient to invoke award under section. 210 C. 423. Does not preclude award of special benefits under Sec. 31-308. 214 C. 181. Cited. Id., 189. Economic benefits qualified as “compensation” under section may include fringe benefits in certain circumstances. Id., 394. Cited. Id., 552; 217 C. 50; 220 C. 721; 222 C. 62; 224 C. 441; 231 C. 287. Benefits awarded under section are subject to review and modification procedures set forth in the Workers' Compensation Act. 252 C. 708. City employer's right to intervene in employee's negligence action against physician is incorporated into section pursuant to Sec. 31-293. 253 C. 429. Benefits paid under section are special compensation and not workers' compensation for purposes of reimbursement from Special Injury Fund pursuant to Sec. 31-306(a)(2)(A) and such a result does not deny employers a protected property interest without due process of law. 269 C. 763. Town constable was not regular member of a paid municipal police department for purposes of receiving benefits under Heart and Hypertension Act. 275 C. 246. Parties' mistake of law regarding applicability of section to their agreements was inaccurate but reasonable, and therefore agreements may not be opened. 296 C. 352. For purposes of determining limitation period under Sec. 31-294c, hypertension claim was properly treated as one for an accidental injury definitely located in time and place, rather than a repetitive trauma injury, because plaintiff failed to present evidence that hypertension was causally connected to employment; formal diagnosis of hypertension or heart disease, communicated to an employee by his or her physician, constitutes the “injury” that triggers the running of the limitation period of Sec. 31-294c. 299 C. 265. Evidence that claimant had elevated blood pressure readings, or had been advised by physician to monitor blood pressure, is insufficient to trigger one year filing period under Sec. 31-294c, rather there must be evidence that claimant knew he or she suffered from hypertension, ordinarily shown by proof claimant was informed of diagnosis by a medical professional. 302 C. 755. Hypertension diagnosis is sufficient to trigger one year filing period under Sec. 31-294c and prescription of hypertension medication is not required. Id., 767. Medical care exception in Sec. 31-294c does not apply to toll statute of limitations under this section because plaintiff failed to establish that employer previously furnished medical care for specific condition or later claimed condition was causally related to timely reported incident for which employer furnished medical care. 304 C. 571. Section's use of disjunctive “hypertension or heart disease” permits plaintiff to file a claim for benefits related to either hypertension or heart disease, and failure to timely file claim for benefits related to hypertension does not bar later timely claim for heart disease. 323 C. 607. Neither Morgan v. East Haven, 208 C. 576, nor any other legal authority barred the substitution of executrix as party claimant to the extent executrix sought payment of matured benefits; under section, matured benefits that accrued during claimant's lifetime properly pass to claimant's estate. 331 C. 672. A claim for heart disease that occurred after an initial compensable claim for hypertension under section may qualify for benefits without the need to file a new notice of claim as long as there is a causal connection between the two injuries. 334 C. 857.

Pension benefits payable under the city's ordinances must be reduced by benefits awarded under statute. 1 CA 58. Purpose of statute is to protect firemen and policemen from economic loss; measure of the loss must be determined by extent to which claimant is precluded from rejoining work force in his former capacity or any other reasonable occupation due to his disability. 2 CA 255. Benefits not retroactively applied; also not applicable to those no longer in active service, either on or off duty. 4 CA 226. Cited. 6 CA 265; 7 CA 142; 12 CA 138. No requirement than an appointment be “permanent”. 13 CA 566. Cited. 17 CA 633; 21 CA 28; 26 CA 194. In order to be eligible for any benefits for either hypertension or heart disease, plaintiff must have successfully passed a preemployment physical showing no evidence of either hypertension or heart disease. 28 CA 754. Cited. 34 CA 307; 37 CA 835. Without evidence establishing claimant's injury is result of an occupational disease, 1-year statute of limitations applies. 38 CA 1. Cited. 43 CA 773. Language of statute clearly and unambiguously mandates that for claimant to be foreclosed from the benefits of the statute, results of the preemployment physical examination must contain evidence of hypertension or heart disease. 56 CA 235. Board incorrectly interpreted Sec. 31-284b as requiring city to continue insurance coverage for plaintiff and his family once plaintiff's compensation payments under section ended. 61 CA 9. Section demonstrates clear policy of creating additional benefits for certain classes of disabled municipal employees. 66 CA 105. Member of municipal fire or police department hired before July 1, 1996, may elect to be covered under either this section or Ch. 568; statute not intended to provide its beneficiaries with dual dollar benefits, but to eliminate two of the basic requirements for coverage under Workers' Compensation Act, i.e. the causal connection between hypertension and heart disease and the employment and requirement that the illness was suffered during the course of employment. 70 CA 321. The legislative history underlying the General Assembly's replacement of the rebuttable presumption with a conclusive presumption in 1996 reveals that the General Assembly intended for all police officers and firefighters hired prior to July 1, 1996, to be grandfathered in, in an effort to balance the financial concerns of municipalities with the expectations of those police officers and firefighters already employed. 190 CA 398. A claimant who forgoes filing a claim within one year of being informed by a medical professional that he or she has a heart disease and who later files a claim for a different heart disease is precluded from receiving benefits under section. Id., 718. The definition of “member” in Sec. 7-425(5) is inapplicable to section because applying that definition would reserve eligibility for heart and hypertension benefits solely for full-time firefighters, which is inconsistent with the plain language of the section and the clear intent of the legislature. 206 CA 223. Plaintiff's employment as chief of police did not constitute a new hire date since there was no break in employment with the police department; there is no language in the section to suggest that heart and hypertension benefits are not available to claimants who continue to serve as regular members of the police department while also receiving pension benefits for prior service with the same employer. 218 CA 720.

Plaintiff not required to assume burden of proving compensability under Ch. 568 where he brought action under both Ch. 568 and this statute. 38 CS 359. Town must have organized police department under Sec. 7-274 in order for this statute to be operative. Id., 419. Cited. 39 CS 321. Claims under statute are subject to procedural requirements of Workers' Compensation Act. Id., 403.

Subsec. (a):

Definition of word “member” in Sec. 7-425(5) applies to use of such word in phrase “a uniformed member of a paid municipal fire department” in Subsec. 346 C. 711.

Benefits may not be awarded concurrently. 57 CA 472.

Notes of Decisions
Cited in 108 cases (14 in the last 5 years), 1973–2026 · leading case: Ciarlelli v. TOWN OF HAMDEN, 8 A.3d 1093 (Conn. 2010).
Ciarlelli v. TOWN OF HAMDEN, 8 A.3d 1093 (Conn. 2010). · cites it 215× “This appeal requires us to determine when the one year limitation period of General Statutes § 31-294c (a) [1] begins to run on a claim for hypertension benefits under General Statutes § 7-433c. [2] The plaintiff, David Ciarlelli, appeals [3] from the decision of the…”
Genesky v. Town of East Lyme, 881 A.2d 114 (Conn. 2005). · cites it 115× “” General Statutes § 7-433c (a). Following its examination of the commissioner’s findings, the board noted that the town had established a constabulary and that it had contracted with the state department of public safety to participate in the resident state trooper program.”
Holston v. New Haven Police Dept., 149 A.3d 165 (Conn. 2016). · cites it 78× “The named defendant, the New Haven Police Department,1 appeals2 from the decision of the Workers’ Compensation Review Board (board), which affirmed the decision of the Workers’ Compensation Commissioner for the Third District (commissioner), awarding heart disease benefits to…”
Brennan v. City of Waterbury, 207 A.3d 1 (Conn. 2019). · cites it 58× “In this appeal, we consider whether heart and hypertension benefits under General Statutes § 7-433c for permanent disability properly are paid to a deceased claimant's estate if such benefits vested and were payable ("matured") during the claimant's lifetime but were not paid to…”
Clark v. Waterford, Cohanzie Fire Dept., 346 Conn. 711 (Conn. 2023). · cites it 116× “) General Statutes § 7-433c (a). We agree with the town and, accordingly, reverse the judgment of the Appellate Court.”
King v. Sultar, 754 A.2d 782 (Conn. 2000). · cites it 68× “General Statutes § 7-433c (a) provides that compensation paid thereunder shall be paid in “the same manner (emphasis added); as that paid under the Workers’ Compensation Act.”
Bergeson v. City of New London, 850 A.2d 184 (Conn. 2004). · cites it 63× “This appeal requires us to determine whether, pursuant to General Statutes § 31-306 (a) (2) (A) 1 of the Workers’ Compensation Act, the second *766 injury fund (fund) 2 is required to reimburse a municipal employer for cost-of-living adjustments (COLAs) paid in connection with a…”
Maciejewski v. Town of West Hartford, 480 A.2d 519 (Conn. 1984). · cites it 47× “The principal issue on this appeal is whether the defendants can lawfully deduct from the plaintiff’s pension benefits, paid to him under the town of West Hartford’s pension ordinance, those benefits which he receives under General Statutes § 7-433c which provides for disability…”
Bakelaar v. City of West Haven, 475 A.2d 283 (Conn. 1984). · cites it 31× “” *62 General Statutes § 7-433c 2 provides benefits for policemen or firemen disabled or dead as a result of hypertension or heart disease.”
Town of Plainville v. Travelers Indem. Co., 425 A.2d 131 (Conn. 1979). · cites it 35× “Consequently, on February 25, the commissioner’s finding and award was issued granting benefits to the claimant in accordance with the provisions of General Statutes § 7-433c. Thereupon, counsel for the plaintiff notified the defendant, Travelers Indemnity Company, that the town…”
Coughlin v. Stamford Fire Dept., 334 Conn. 857 (Conn. 2020). · cites it 42× “The named defendant, the Stamford Fire Department,1 appeals2 from the decision of the Compen- sation Review Board (board), which reversed the deci- sion of the Workers’ Compensation Commissioner for the Seventh District (commissioner) denying benefits to the plaintiff, John…”
Morgan v. Town of East Haven, 546 A.2d 243 (Conn. 1988). · cites it 46× “*579 Subsequent to his heart failure, Morgan applied to the town of East Haven for benefits pursuant to General Statutes § 7-433c. After a hearing, the commissioner issued a finding and award on January 26,1983.”
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