Matter of Daly v. New York City Off. of Mgt. & Budget
Dante E. Daly, a budget analyst for the New York City Office of Management & Budget (OMB), filed a claim for workers' compensation benefits, alleging injuries from World Trade Center (WTC) toxin exposure after the 9/11 attacks. He claimed participation in WTC rescue, recovery, and cleanup operations by performing budgetary analysis for these efforts. The Workers' Compensation Law Judge (WCLJ) and the Workers' Compensation Board denied his claim, finding his activities were not covered by Workers' Compensation Law article 8-A as he was not a direct participant. The Appellate Division, Third Department, affirmed this decision, concurring that claimant's job duties as a budget analyst lacked a direct or tangible connection to the WTC rescue, recovery, or cleanup operations. The Court also addressed and dismissed claimant's procedural arguments regarding OMB's alleged waiver of defenses.