Buffalo Civic Auto Ramps, Inc. v. Serio
This CPLR article 78 proceeding reviewed a determination by the Superintendent of Insurance, dated January 29, 2003, which reclassified parking ramp cashiers of Buffalo Civic Auto Ramps, Inc. (BCAR) from clerical "office employees" (Code 8810) to "automobile parking lot and drivers" (Code 8392) for workers’ compensation purposes. BCAR challenged this reclassification, arguing it was unsupported by substantial evidence and arbitrary and capricious, as their cashiers' duties were comparable to other clerical workers classified under Code 8810. The court found the Superintendent's determination lacked substantial evidence, noting no proof of increased hazard for BCAR cashiers compared to pari-mutuel clerks or bus terminal cashiers. The court also deemed the determination arbitrary and capricious due to inconsistent treatment of similarly situated cashiers. Consequently, the court vacated and annulled the Superintendent's determination and remanded the matter to the New York Compensation Insurance Rating Board for further proceedings.