Washington Law Review


The recent case of Windust v. Department of Labor and Industries brought an important change in Washington workmen's compensation law with the overruling of a long-standing rule relating to recovery under workmen's compensation for heart failure. The Windust case apparently means there can be recovery for heart failure resulting from strain only when the strain is "unusual." It appears that if the worker is doing only a routine act there can be no recovery. Though the new rule is not definitively articulated at this point, this inquiry will attempt to assess what the Washington Supreme Court has done and indicate what it will do in the future.

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