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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

Scodary v. Serritella

Claimant established a work-related neck and left arm injury, receiving workers’ compensation benefits for a brief period in December 2003. Her employment was terminated in January 2004, leading to new issues regarding further causally related disability, consequential depression, and withdrawal from the labor market. Both a Workers’ Compensation Law Judge and the Workers’ Compensation Board denied her claim for consequential depression, asserting that her psychologist's treatment lacked the required referral from an authorized physician under Workers’ Compensation Law § 13-m (2) (a). The appellate court ruled this exclusion of evidence was an error, stating the statute does not create an evidentiary barrier to a psychologist's testimony and records, even without a physician referral. Consequently, the court modified the Board's decision, reversing the exclusion of evidence for consequential depression, and remitted the case for further proceedings.

Workers' Compensation BenefitsConsequential DepressionPsychologist TestimonyReferral RequirementEvidentiary StandardsCausally Related DisabilityLoss of EarningsAppellate ReviewRemittalMedical Evidence Admissibility
References
3
Case No. MISSING
Regular Panel Decision
Apr 09, 2009

Claim of Smith v. Cornell University

Decedent, a painter, suffered work-related injuries in 2000 and 2001, leading to a workers’ compensation claim established for consequential depression. In 2007, he committed suicide. His wife, the claimant, sought death benefits, arguing the suicide stemmed from his work injuries, chronic pain, and depression. The Workers’ Compensation Board affirmed the claim, finding substantial medical evidence from the treating psychiatrist and an independent medical examiner supported a causal link between the 2001 accident, subsequent depression, and suicide. The Board also concluded that a compensable accident only needs to be a contributing cause to a mental injury, thus affirming the causal relationship despite other potential factors.

SuicideDepressionWork-related injuryCausationDeath benefitsWorkers' Compensation LawChronic painMental healthMedical evidenceAppellate review
References
5
Case No. MISSING
Regular Panel Decision
Dec 14, 2010

Francis v. Jewelry Box Corp. of America

Claimant sustained a work-related crush injury to his right hand in 1987 and was granted a lump-sum nonschedule adjustment in 1993, closing his case. He subsequently sought to reopen his claim, submitting a psychologist's report alleging total disability due to chronic major depression, posttraumatic stress disorder, and chronic pain disorder stemming from the original accident. The Workers’ Compensation Board denied his application, citing his prior waiver of the right to establish a psychiatric injury and insufficient proof of an unanticipated change in his established condition. The Appellate Division affirmed the Board's decision, concluding that the claimant failed to demonstrate an unanticipated change in his medical condition that would warrant reopening the claim, especially given his prior waiver regarding psychiatric injury.

Workers' CompensationPermanent Partial DisabilityLump-Sum SettlementReopening ClaimPsychiatric InjuryWaiver of RightsChange in ConditionWorkers' Compensation BoardAppellate DivisionAffirmed Decision
References
2
Case No. MISSING
Regular Panel Decision
Nov 17, 1977

Daigneault v. Allegheny Ludlum Steel Corp.

The Workers’ Compensation Board found that the claimant developed chronic bronchitis precipitating emphysema, which was causally related to their employment due to exposure to irritating factors, leading to disability. This decision, filed on November 17, 1977, was appealed. The appellate court affirmed the board's determination, concluding that there was substantial medical evidence to support the finding. Costs were awarded to the Workers’ Compensation Board against the self-insured employer.

Chronic BronchitisEmphysemaCausally Related EmploymentDisabilityMedical EvidenceWorkers' Compensation AppealSelf-Insured EmployerBoard Decision
References
1
Case No. MISSING
Regular Panel Decision
Jul 25, 2001

Claim of Multari v. Keenan Oil Co.

The claimant appealed a Workers' Compensation Board decision from July 25, 2001, which found that a section 32 waiver agreement included his major depression condition. The claimant had settled two compensation cases from 1972 and 1994 for $93,000, closing both. He later argued the agreement failed to cover his major depression, established in 1996 in conjunction with the 1994 accident. The Board affirmed its jurisdiction and rejected the claimant's contention that the major depression was excluded. The appellate court agreed the Board had jurisdiction to determine if a condition was included in a section 32 agreement. On the merits, the court found the Board correctly concluded the major depression condition was subsumed in the settlement, citing the agreement's unequivocal terms and the claimant's hearing testimony. The agreement stated cases could not be reopened "for any purpose whatsoever" and permanently discontinued weekly benefits that included compensation for depression.

Workers' CompensationSettlement AgreementWaiver AgreementMajor DepressionPsychiatric ConditionJurisdictionSection 32 AgreementAppealBoard ReviewScope of Agreement
References
4
Case No. MISSING
Regular Panel Decision

Klett v. Barnhart

Plaintiff Christopher Klett sought judicial review of a decision by the Commissioner of the Social Security Administration denying his claim for Children's Insurance Benefits. Klett argued he was disabled before age 22 due to Tourette's Syndrome and chronic depression. The Administrative Law Judge (ALJ) rejected Klett's claim, finding that while retrospective medical diagnoses supported his disability, they were contradicted by compelling non-medical evidence such as Klett's college graduation with a B+ average and a professor's recommendation. The District Court affirmed the Commissioner's decision, concluding that the ALJ's denial was supported by substantial evidence. Consequently, Klett's motion for judgment on the pleadings was denied, and the Commissioner's cross-motion was granted.

Social Security ActChildren's Insurance BenefitsDisability ClaimTourette's SyndromeChronic DepressionAdministrative Law Judge (ALJ)Retrospective DiagnosisSubstantial Evidence ReviewMedical EvidenceNon-Medical Evidence
References
13
Case No. MISSING
Regular Panel Decision

Rackley v. County of Rensselaer

A caseworker employed by the Rensselaer County Department of Social Services filed a workers' compensation claim for mental stress, citing a heavy caseload as the cause. Initially, an Administrative Law Judge dismissed the claim, stating a lack of specific psychic trauma. However, the Workers' Compensation Board reversed this decision, finding that the claimant's chronic depression and disablement stemmed from their demanding work environment. The self-insured employer subsequently appealed the Board's determination. The court affirmed the Board's decision, clarifying that mental injury does not require a discrete psychic trauma and can arise from prolonged emotional stress, even if the underlying cause is common to similarly employed individuals.

Mental InjuryEmotional StressPsychic TraumaChronic DepressionWork-Related InjuryCaseloadWorkers' Compensation BoardAppealEmployer LiabilityMedical Testimony
References
10
Case No. MISSING
Regular Panel Decision

Vitale v. Apfel

Plaintiff Peter Vitale sought judicial review of a final determination by the Commissioner of Social Security, which denied his application for disability insurance benefits. The Commissioner subsequently moved for judgment on the pleadings. Plaintiff alleged disability since November 1980 due to chronic back/neck pain and depression, with his insured status expiring in December 1985. The court reviewed the Administrative Law Judge's (ALJ) decision, finding it supported by substantial evidence. It concluded that the medical evidence was insufficient to prove disability before his insured status expired and that subjective evidence alone could not sustain his burden of proof. Consequently, the Commissioner's motion for judgment on the pleadings was granted, and judgment was entered against the plaintiff.

Social Security ActDisability Insurance BenefitsJudicial ReviewAdministrative Law Judge (ALJ)Appeals CouncilChronic Back PainDepressionInsured StatusMedical Evidence SufficiencyTreating Physician Opinion
References
12
Case No. MISSING
Regular Panel Decision
Feb 11, 2009

Corson v. Astrue

This case involves an appeal of the Commissioner's decision to deny Social Security Disability Insurance (SSDI) benefits to Arnell M. Corson. Plaintiff Corson suffers from chronic neck and back discomfort and depression. Magistrate Judge Leslie G. Foschio recommended granting the defendant's motion for judgment on the pleadings and denying the plaintiff's cross-motion for summary judgment. Chief Judge Richard J. Arcara adopted this recommendation, finding that the Administrative Law Judge's (ALJ) decision was supported by substantial evidence. The court concluded that Corson retained the residual functional capacity to perform a full range of unskilled sedentary work, despite her impairments, and was therefore not disabled.

Social Security DisabilitySSDI Benefits AppealFunctional CapacitySedentary WorkAffective DisorderDegenerative Disc DiseaseChronic PainResidual Functional CapacityAdministrative Law Judge DecisionTreating Physician Rule
References
29
Case No. MISSING
Regular Panel Decision

Calabrese v. Astrue

Darlene Calabrese sought judicial review under 42 U.S.C. § 405(g) of a final determination by the Commissioner of Social Security, which found her not disabled. After a prior remand, ALJ Bruce Mazzarella's decision became final, prompting this district court action. Plaintiff moved for judgment on the pleadings, and the Commissioner cross-moved. Presiding District Judge David G. Larimer affirmed the Commissioner's decision, concluding it was supported by substantial evidence from a vocational expert, despite Calabrese's severe impairments including chronic pain, borderline IQ, and depression/anxiety disorder. The court found that the ALJ's hypothetical to the vocational expert adequately accounted for the plaintiff's limitations. Consequently, the plaintiff's complaint was dismissed with prejudice.

Social Security DisabilityMental ImpairmentDepressive DisorderAnxiety DisorderBorderline IQVocational Expert TestimonyResidual Functional CapacitySedentary WorkAppeals CouncilAdministrative Law Judge
References
17
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