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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
Feb 22, 1984

Barnhardt v. Hudson Valley District Council of Carpenters Benefit Funds

The plaintiff, injured in May 1978 during maintenance work, was denied workers' compensation due to the absence of an employer-employee relationship. Subsequently, he sought reimbursement for medical expenses from the Hudson Valley District Council of Carpenters Benefit Funds (Benefit Funds) through a union insurance policy. Continental Assurance Company (Continental), Benefit Funds' insurer, rejected the claim, citing an employment-related injury exclusion in the policy. The plaintiff then initiated an action against Benefit Funds, which in turn filed a third-party action against Continental seeking indemnification. Continental's motion for summary judgment, asserting the exclusion, was denied by the County Court. The appellate court affirmed this denial, ruling that the exclusionary language was ambiguous and applied only in cases where a clear employer-employee relationship existed, a fact still to be determined.

Insurance Policy InterpretationEmployment StatusWorkers' Compensation ExclusionSummary Judgment MotionContractual AmbiguityGroup Health InsuranceMedical Expense ReimbursementThird-Party ActionAppellate ReviewEmployer-Employee Relationship
References
10
Case No. MISSING
Regular Panel Decision

Truly v. Regan

Petitioner, employed by Brooklyn Developmental Center, sustained a lower back and left leg injury in January 1986. After a period of inactivity, she stopped working in March 1987 due to her injuries and began receiving workers' compensation benefits. In February 1988, her applications for ordinary disability retirement benefits (under Retirement and Social Security Law art 14) and article 15 disability retirement benefits (under art 15) were denied by the respondent. The ordinary disability application was denied because she was not 'in service' at the time of filing, having been terminated in May 1987. The article 15 disability application was deemed untimely, as it was filed in February 1988, beyond the three-month window from her last payroll date of March 27, 1987, and she lacked approved medical leave. The court confirmed the denial and dismissed her petition.

Disability RetirementOrdinary Disability BenefitsArticle 15 Disability BenefitsIn Service RequirementTimely FilingCPLR Article 78 ProceedingEmployment TerminationMedical LeaveNew York State Employees' Retirement SystemAlbany County
References
5
Case No. MISSING
Regular Panel Decision
Dec 20, 2000

Sutherland v. Village of Suffern

The petitioner, a police officer, was injured while attempting to open a door at the station house and subsequently applied for benefits under General Municipal Law § 207-c. The Chief of the Village of Suffern Police Department denied these benefits, leading the petitioner to initiate an Article 78 proceeding. The Supreme Court, Rockland County, denied the petition and dismissed the case. On appeal, the judgment was affirmed, with the court citing *Matter of Balcerak v County of Nassau* to underscore that General Municipal Law § 207-c is intended for injuries arising from heightened risks associated with criminal justice duties, concluding the denial was not arbitrary or capricious. The court also clarified that claims for Workers' Compensation benefits should be addressed to the Workers’ Compensation Board.

Police officer injuryGeneral Municipal Law 207-c benefitsDenial of benefitsScope of employmentAdministrative reviewCPLR Article 78Appellate Division decisionWorkers' Compensation jurisdictionMunicipal employee benefitsSuffern Police Department
References
2
Case No. MISSING
Regular Panel Decision
Nov 02, 2001

Claim of Medina v. Building Maintenance Service

Claimant sustained work-related injuries in July 1999. Her physician, Dr. Magdy Elamir, failed to file medical reports with the Workers' Compensation Board after August 1999 and before April 18, 2001, and with the State Insurance Fund until April 18, 2001. This led to a controversy over insurance coverage between Fireman’s Fund and State Fund. Initially, a WCLJ awarded benefits, but the Board rescinded the award for October 4, 1999, to April 18, 2001, citing prejudice to State Fund. On appeal, the court determined that State Fund was not prejudiced from October 4, 1999, to December 21, 2000, and reversed that part of the Board's decision, while affirming the denial of benefits from December 21, 2000, to April 18, 2001.

Workers' CompensationMedical Report FilingPrejudiceInsurance Coverage DisputeDenial of BenefitsAppellate ReviewAdministrative DeterminationSubstantial EvidenceRegulatory ComplianceNeurologist
References
7
Case No. MISSING
Regular Panel Decision
Feb 02, 1984

Krebbeks v. Regan

Petitioner, the widow of a Department of Transportation employee, applied for accidental death benefits after her husband's service-connected death in July 1981. Although her application for accidental death benefits was approved, these benefits were entirely offset by workers' compensation payments, leaving her with no current payments from the State Employees’ Retirement System. Subsequently, petitioner sought a lump-sum ordinary death benefit, which was denied because she was deemed eligible for accidental death benefits, even if offset. This appeal ensued after the denial of her application by a hearing officer and Special Term's concurrence. The court affirmed the denial, citing Retirement and Social Security Law § 60 (a) (3), which states an ordinary death benefit is not payable if an accidental death benefit is payable, with a narrow exception not applicable here.

Accidental Death BenefitsOrdinary Death BenefitsWorkers' Compensation OffsetRetirement and Social Security LawStatutory InterpretationDeath Benefits EligibilityPublic Employee BenefitsAdministrative Law AppealDeath Benefit Offset
References
2
Case No. MISSING
Regular Panel Decision

York v. Comm'r of Soc. Sec.

The plaintiff appealed the Commissioner of Social Security's denial of disability benefits. An Administrative Law Judge (ALJ) initially found the plaintiff not disabled, a decision affirmed by the Appeals Council. The plaintiff subsequently moved for judgment on the pleadings, requesting a remand for benefits or further administrative proceedings. The court found that the ALJ erred in evaluating the plaintiff's spinal impairments under Listing 1.04 and in assessing medical opinion evidence from Dr. Harbinder Toor. Consequently, the court granted the plaintiff's motion, denied the Commissioner's cross-motion, and remanded the case for further proceedings, including a reassessment of Listing 1.04 and reconsideration of Dr. Toor's opinion.

Disability BenefitsSocial Security ActALJ Decision ReviewRemandLumbar Spinal StenosisDegenerative Disc DiseaseMedical Opinion EvidenceResidual Functional Capacity (RFC)Vocational Expert TestimonyAppeals Council
References
7
Case No. Dkt. # 6, Dkt. # 7
Regular Panel Decision
Feb 05, 2013

Crayton v. Astrue

Plaintiff appeals the denial of supplemental security income benefits by the Commissioner of Social Security. Plaintiff filed an application for Supplemental Security Income benefits in 2009, alleging inability to work due to various medical conditions. An Administrative Law Judge (ALJ) denied the application, and the Appeals Council denied review, making the ALJ's decision final. The District Court reviews the Commissioner's decision, finding that while the ALJ's assessment of exertional limitations was supported by substantial evidence, the ALJ failed to apply the Psychiatric Review Technique (PRT) in analyzing non-exertional limitations. Consequently, the court remands the matter for further proceedings consistent with its opinion, specifically for proper application of the PRT.

Supplemental Security IncomeSocial Security ActDisability BenefitsAdministrative Law JudgePsychiatric Review TechniqueRFCExertional LimitationsNon-exertional LimitationsDepressionAnxiety
References
15
Case No. 2017-06-1778
Regular Panel Decision
Apr 11, 2018

Demotte, Julie v. UPS

Julie Demotte sustained a workplace injury involving a broken hip and leg in November 2016 while working for UPS. UPS initially accepted the claim and provided temporary disability benefits. Dr. Jason Evans, the authorized treating physician, placed Ms. Demotte at maximum medical improvement and assigned a three-percent whole-person impairment rating. A compensation hearing was held to determine Ms. Demotte's entitlement to permanent disability, temporary disability, and future medical benefits. The Court ordered UPS to provide lifetime medical benefits for Ms. Demotte's workplace injury, but denied her claims for both temporary and permanent disability benefits. The denial of permanent disability was based on the inadmissibility of Form C-30A as proof of impairment, as Ms. Demotte failed to present admissible evidence. Additionally, the claim for further temporary disability benefits was denied due to an earlier overpayment by UPS that exceeded any subsequent amounts due.

Workplace InjuryFuture Medical BenefitsTemporary Disability BenefitsPermanent Disability BenefitsAdmissibility of Medical ReportsForm C-30AForm C-32Impairment RatingHearsayMaximum Medical Improvement
References
2
Case No. MISSING
Regular Panel Decision

Hand v. Stevens Transport, Inc. Employee Benefit Plan

Jean and Howard Hand appealed the trial court's grant of summary judgment which dismissed their claims for health care benefits against the Stevens Transport, Inc. Employee Benefit Plan as time-barred. The Hands argued that the Plan's failure to comply with ERISA's notification requirements should invalidate or toll the contractual limitations period. The appellate court found that while the Plan's notice was non-compliant, it still provided reasonable notice of partial denial, and the Hands failed to exercise due diligence. The court concluded that the twenty-seven month contractual limitations period was reasonable and was not tolled by the Plan's ERISA non-compliance or the pursuit of administrative remedies. Therefore, the Hands' claims were barred, and the trial court's judgment was affirmed.

ERISAHealth Insurance BenefitsContractual Limitations PeriodStatute of LimitationsSummary JudgmentDenial of BenefitsEquitable TollingAdministrative RemediesNotice RequirementsEmployee Benefit Plan
References
19
Case No. MISSING
Regular Panel Decision

Furch v. Bucci

A firefighter for the City of Binghamton sought supplemental wage benefits under General Municipal Law § 207-a, claiming arteriosclerosis and acute myocardial infarction were job-related. After initial denials and an administrative hearing, the application was again denied. The Supreme Court partially dismissed his CPLR article 78 petition but transferred a substantial evidence question to this Court. This Court affirmed due process and the non-binding nature of a workers' compensation decision regarding arteriosclerosis. However, it ruled that respondents were bound by the workers' compensation finding that the myocardial infarction was causally related to employment. Consequently, the matter was remitted to determine the petitioner's entitlement to benefits for any period of disability solely attributable to the myocardial infarction.

Firefighter benefitsGeneral Municipal Law Section 207-aWorkers' Compensation LawCPLR Article 78Myocardial InfarctionArteriosclerosisCausal RelationDue ProcessAdministrative LawRes Judicata
References
7
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