State Trooper’s Heart Attack Qualifies For Disability Pension After Court Rejects Strict Causation Standard

Written on 10/10/2025
LRIS

Lieutenant Staci K. Shepherd, a 22-year veteran of the Rhode Island State Police with an exemplary record, suffered a heart attack on May 2, 2017, during firearms requalification training. Earlier that day, she had experienced intermittent arm pain and sternum discomfort but proceeded with the training. Immediately after completing the course, she collapsed with cardiac arrest, underwent emergency surgery for two stents, and later received a third. Her cardiologist confirmed that she could no longer perform full-duty work due to permanent heart damage and fatigue. Shepherd applied for a disability pension under R.I. Gen. Laws § 42-28-21, which entitles officers to 75% of their salary if injured “in the course of performance of… duties.”

Superintendent James Manni denied the pension after a quasi-judicial hearing, concluding Shepherd failed to prove her heart attack was causally linked to her duties. Though he acknowledged her disability was permanent, he applied a stringent causation standard from workers’ compensation cases, requiring proof the attack occurred because of her work. He dismissed evidence of job-related stressors — irregular hours, administrative pressures, and poor dietary habits — despite testimony from the State’s own medical expert, who admitted these factors could contribute to heart disease but stated no physician could confirm causation “with clinical certainty.”

Shepherd sued in Superior Court, which declared Manni’s decision “arbitrary and capricious” and granted her the pension.

The Rhode Island Supreme Court affirmed, but on different grounds. Writing for the majority, Justice Goldberg held the superintendent misapplied the legal standard by demanding proximate cause akin to negligence cases. Instead, the Court ruled the correct heart-attack specific test was whether employment contributed to the injury, per Mulcahey v. New England Newspapers, Inc., which held that “it is enough if the conditions and nature of the employment contribute to the injury.” The majority found this standard met: Shepherd had no prior cardiac issues or family history, and her job’s stresses were undisputed contributors to her injury.

The Court declined to remand, citing its supervisory authority and the fully documentary record. The pension was affirmed retroactively.

Shepherd v. R.I. State Police, 338 A.3d 289 (R.I. 2025).