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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

Gibson v. American Export Isbrandtsen Lines, Inc.

John Gibson, a seaman, suffered a heart attack in 1970 while working aboard the vessel Seawitch. His wife, Anna Gibson, subsequently initiated an action in February 1977 against his employer, American Export Isbrandtsen Lines, claiming damages for loss of consortium. American Export sought to dismiss her complaint, contending that spouses of injured seamen lacked a claim for loss of consortium under general maritime law at the time, and that the landmark Supreme Court decision in American Export Lines v Alvez (1980), which established this right, should not be retroactively applied. The court thoroughly reviewed the evolution of maritime law concerning loss of consortium, referencing key decisions such as Moragne (1970), Sea-Land Servs. v Gaudet (1974), and Alvez (1980). Ultimately, the court denied American Export's motion, ruling that the Alvez decision should be applied retroactively to cases like Mrs. Gibson's, where the plaintiff was actively challenging existing legal precedents prior to the Alvez ruling.

RetroactivityLoss of ConsortiumMaritime LawSeaman's RightsPersonal InjuryGeneral Maritime LawSpousal ClaimsFederal Maritime LawAppellate ReviewTort Law
References
16
Case No. 2017 NY Slip Op 04184 [150 AD3d 1589]
Regular Panel Decision
May 25, 2017

New York State Workers' Compensation Board v. Program Risk Management, Inc.

The New York State Workers' Compensation Board, acting as administrator and successor to the Community Residence Insurance Savings Plan, initiated legal action against various entities and individuals after the trust became severely underfunded. Defendants include Program Risk Management, Inc. (administrator), PRM Claims Services, Inc. (claims administrator), individual officers of PRM, the Board of Trustees, and Thomas Gosdeck (trust counsel). The plaintiff sought damages for claims such as breach of contract, breach of fiduciary duty, and legal malpractice. The Supreme Court's order partially dismissed some claims and denied others. On cross-appeal, the Appellate Division, Third Department, modified the Supreme Court's order, notably reversing the dismissal of several breach of fiduciary duty claims and common-law indemnification against PRMCS, while affirming denials of motions to dismiss breach of contract, legal malpractice, and unjust enrichment claims. The court's decision was influenced by recent rulings in State of N.Y. Workers' Compensation Bd. v Wang.

Workers' Compensation LawGroup Self-Insured TrustBreach of ContractBreach of Fiduciary DutyLegal MalpracticeUnjust EnrichmentStatute of LimitationsEquitable EstoppelAlter Ego LiabilityCommon-Law Indemnification
References
20
Case No. MISSING
Regular Panel Decision

American Prescription Plan, Inc. v. American Postal Workers Union AFL-CIO Health Plan

This case involves appeals and a cross-appeal from an order of the Supreme Court, Nassau County. Defendant American Postal Workers Union, AFL-CIO Health Plan (APWU-HP) appealed the denial of its motion for summary judgment concerning the fourth, fifth, and fourteenth causes of action. Defendant Administrative Consultants, Inc. (ACI) appealed the denial of its motion for summary judgment regarding the tenth and eleventh causes of action. The plaintiff cross-appealed the partial dismissal of the first, third, and sixth causes of action. The appellate court reversed the order for the defendants, granting their motions for summary judgment and dismissing all causes of action asserted against them. The order was affirmed insofar as cross-appealed by the plaintiff, upholding the partial dismissals against the plaintiff.

Summary JudgmentContract DisputeOral RepresentationsStatute of FraudsEquitable EstoppelAppellate ProcedureDismissal of ClaimsBreach of ContractMootness DoctrineAuthority to Contract
References
7
Case No. ADJ2901317 (FRE0226671)
Regular
May 02, 2011

Connie Mehia vs. CITY OF FRESNO C/O AMERICAN ALL RISK LOSS ADMINISTRATORS (AARLA)

The applicant sought workers' compensation benefits for a stroke, claiming it arose out of and in the course of employment due to workplace stress. The Administrative Law Judge (WCJ) denied the claim, finding no credible evidence that a workplace incident caused the stroke. The Workers' Compensation Appeals Board (WCAB) affirmed the WCJ's decision, concluding that the applicant failed to prove the crucial element of a work-related precipitating event. Both QMEs opined the stroke could be industrially related, but their opinions relied on the applicant's account of a specific workplace argument that the WCJ found unsubstantiated.

AOE/COEindustrial strokeworkers' compensationreconsiderationcausationpre-existing conditionQualified Medical Examinercredibilitysubstantial evidencework-related stress
References
0
Case No. 2025 NY Slip Op 04576 [241 AD3d 563]
Regular Panel Decision
Aug 06, 2025

New York Bus Operators Compensation Trust v. American Home Assur. Co.

The New York Bus Operators Compensation Trust (NYBOCT), a self-insured entity, brought an action against its excess-of-loss insurer, American Home Assurance Co., alleging breach of contract and seeking declaratory relief. This dispute arose after American Home denied coverage for a workers' compensation claim due to untimely notice. The Supreme Court granted American Home's motion to dismiss the complaint as time-barred, which NYBOCT appealed. The Appellate Division affirmed the Supreme Court's decision, ruling that the six-year statute of limitations for breach of contract began when American Home disclaimed coverage on May 18, 2012, making NYBOCT's 2020 lawsuit untimely. The court rejected arguments related to the continuing-wrong doctrine and estoppel.

Limitation of ActionsBreach of ContractInsurance ContractDisclaimer of CoverageStatute of LimitationsWorkers' CompensationExcess-of-Loss PolicySelf-Insured TrustUntimely NoticeAppellate Review
References
29
Case No. ADJ6624824
Regular
Sep 24, 2012

Andre Williams vs. CITY OF FRESNO, AMERICAN ALL RISK LOSS ADMINISTRATORS

This case concerns applicant Andre Williams' claim for a cumulative trauma psychiatric injury against the City of Fresno. The defendant sought reconsideration of an award finding industrial injury and ordering temporary disability benefits, arguing the claim was barred by Labor Code section 3208.3. The Appeals Board granted reconsideration, accepting supplemental evidence of the applicant's worsening condition and subsequent treatment. The Board deferred findings on the applicant's permanent and stationary date, permanent disability, and need for further medical treatment, returning the matter for further proceedings.

Workers' Compensation Appeals BoardPetition for ReconsiderationFindings of Fact and AwardQualified Medical EvaluatorLabor Code Section 3208.3Cumulative TraumaPsyche InjuryPermanent and Stationary DatePermanent DisabilityFurther Medical Treatment
References
0
Case No. ADJ7247116 ADJ7241415 ADJ7407598 ADJ9052220 ADJ9432209
Regular
Feb 12, 2015

DOROTHY TRISTAN vs. CITY OF FRESNO, AMERICAN ALL-RISK LOSS ADMINISTRATORS

The Workers' Compensation Appeals Board denied the employer's petition for removal regarding a discovery order. The employer argued that releasing documents related to a prior DFEH/EEOC discrimination claim and allowing a continued deposition would cause irreparable harm due to privilege concerns. The Board found the employer failed to demonstrate substantial prejudice or irreparable harm, emphasizing that privilege objections can still be raised for specific documents. The Board also noted the prolonged discovery dispute and encouraged expeditious resolution of the underlying workers' compensation claims.

Petition for RemovalMotion to QuashDepositionDocument ProductionPrivileged RecordsDFEHEEOCLabor Code Section 132aDiscovery DisputeMandatory Settlement Conference
References
4
Case No. ADJ8672614
Regular
Aug 07, 2015

ROBERT OSBORN vs. COUNTY OF FRESNO, AMERICAN ALL RISK LOSS ADMINISTRATORS

This case involves Robert Osborn, a correctional sergeant, who filed a workers' compensation claim for Hepatitis C contracted in 2006. The County of Fresno is challenging the finding that the presumption of injury under LC 3212.8 applies to a correctional sergeant, arguing the applicant did not prove specific exposure or that the injury was work-related. The Workers' Compensation Appeals Board denied the defendant's petition for reconsideration, adopting the WCJ's report which found the presumption applicable to the applicant's role. The WCJ determined that correctional sergeants are engaged in "active law enforcement" and that LC 3212.8 does not require proof of specific exposure, only that the disease manifested during service.

Workers' Compensation Appeals BoardPetition for ReconsiderationWorkers' Compensation Administrative Law JudgeCorrectional SergeantHepatitis CPresumption of InjuryLC 3212.8Active Law EnforcementCustodial EmergenciesCumulative Trauma
References
4
Case No. ADJ1576347 (FRE 0235267) ADJ8047239
Regular
Sep 12, 2013

MICHAEL MANFREDI vs. CITY OF FRESNO, AMERICAN ALL-RISK LOSS ADMINISTRATORS

The Workers' Compensation Appeals Board denied Michael Manfredi's petition for reconsideration. Manfredi, a police officer, sought to establish two separate cumulative trauma injuries for his coronary artery disease and hypertension, rather than the single injury found by the WCJ. The Board affirmed the WCJ's finding that the continuous need for medical treatment between periods of exposure constituted a single compensable injury, citing *Western Growers*. Therefore, the original award of 20% permanent disability stands.

Cumulative traumacoronary artery diseasehypertensionpermanent disabilityreconsiderationJoint Findings of Fact and AwardWCJ ReportWestern Growers v. Workers' Comp. Appeals Board (Austin)separate injuriessingle injury
References
1
Case No. ADJ8457565
Regular
Sep 22, 2015

MELANIE HATHAWAY vs. COUNTY OF FRESNO, AMERICAN ALL RISK LOSS ADMINISTRATORS

In Hathaway v. County of Fresno, the Workers' Compensation Appeals Board granted reconsideration and deferred issues of temporary disability and self-procured medical treatment. The Board found that the applicant's pre-designated physician status may have rendered the defendant's denial of an out-of-network specialist improper under then-existing regulations. Therefore, the case was remanded to determine if the defendant's authorization denial was erroneous before assessing liability for the applicant's self-procured surgery and associated temporary disability.

Workers' Compensation Appeals BoardPetition for ReconsiderationFindings of Fact and AwardTemporary DisabilitySelf-Procured Medical TreatmentSpinal Fusion SurgerySecond Opinion Spinal SurgeryMedical Provider Network (MPN)Predesignation of Personal PhysicianLabor Code § 4062(b)
References
3
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