Claim of Davis v. T.J. Madden Construction Co.
Claimant suffered two work-related knee injuries in 1988 and 1992, leading to separate compensation cases. In April 1999, an application to reopen the 1988 case was filed, supported by a medical report indicating a change in the claimant's condition. The carrier for the 1988 case sought to shift liability to the Special Fund for Reopened Cases and requested reopening of the 1992 case. The Workers' Compensation Board reversed a Law Judge's decision, discharging the Special Fund from liability and placing Travelers Property Casualty (1992 carrier) back on notice. The Appellate Division affirmed the Board's decision, finding that the April 1999 medical report, despite explicitly referencing only the 1988 case, constituted sufficient notice to reopen the interconnected 1992 case within the seven-year statutory period.