Matter of Love v. Village of Pleasantville
Claimant, Richard Love, Chief of Police for the Village of Pleasantville, sought workers' compensation benefits for injuries from a motor vehicle accident. The employer and carrier initially waived defenses by failing to timely serve a prehearing conference statement, a determination upheld in a prior appeal. Although a Workers' Compensation Law Judge and the Board found a causal relationship, the Appellate Division, Third Department, reversed this decision. The court ruled that despite the waiver of defenses, the claimant still bore the burden of proving a causal nexus between his employment and the accident. Finding that Love failed to demonstrate this nexus, as the accident occurred during a personal weekend trip, the court reversed the Board's decision and remitted the matter for further proceedings.