Clark v. Nashville MacHine Elevator Co.
The employee, Eddie W. Clark, Jr., suffered a fatal heart attack while driving home from work in his employer's vehicle. His widow and son were awarded death benefits by the trial court. The employer, Nashville Machine Elevator Co., Inc., appealed, arguing the heart attack was not causally related to employment activities and that no physical exertion occurred at the moment of the heart attack. The Supreme Court affirmed the trial court's decision, finding that physical exertion or strain is not required at the instant of a heart attack if there is evidence linking employment activities to it. Medical testimony indicated that the physical demands of the job 'could have' or 'might have' caused the heart attack, which was deemed sufficient for causation.