Ace Fire Underwriters Insurance Company v. Special Funds Conservation Comittee
An employee of Coca-Cola Bottling Company sustained a work-related injury in March 2007 and was awarded workers’ compensation benefits, payable by Ace Fire Underwriters Insurance Company. The employee was classified with a permanent partial disability, making the Special Disability Fund responsible for reimbursing Ace Fire after 260 weeks under Workers’ Compensation Law § 15 (8). The injured employee settled a third-party personal injury action with Ace Fire's approval, but without the Special Disability Fund's consent. Ace Fire then commenced a proceeding to compel the Special Disability Fund's consent nunc pro tunc under Workers’ Compensation Law § 29 (5). The Court of Appeals held that if the Special Disability Fund's consent is required as a lienor under section 29 (1), the failure to obtain it can be cured by a court order nunc pro tunc under section 29 (5). The order of the Appellate Division was reversed, and the matter remitted to Supreme Court for further proceedings.