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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision
Nov 24, 1992

PINE BARRENS v. Planning Bd.

This case addresses whether the State Environmental Quality Review Act (SEQRA) mandates a cumulative impact statement for over 200 proposed development projects in the Central Pine Barrens region of Long Island. The Central Pine Barrens is a vital ecological area, serving as the sole natural source of drinking water for millions and harboring numerous endangered species, leading to various protective legislations. The Court of Appeals reversed the Appellate Division's ruling, determining that a mandatory cumulative impact study under SEQRA is not applicable here because there is no overarching governmental 'plan' for development in the region, only general protective policies. The court emphasized that comprehensive planning for this area should be conducted by the Long Island Regional Planning Board as outlined in ECL article 55, rather than through individual SEQRA assessments. It also noted the significant delay in the Regional Planning Board's action, urging legislative intervention to address this pressing environmental concern.

Environmental LawSEQRACumulative ImpactPine BarrensSuffolk CountyLong IslandAquifer ProtectionLand Use PlanningState Environmental Quality Review ActPlanning Board
References
6
Case No. 12 Civ. 5645(KPF)
Regular Panel Decision
Feb 18, 2015

Wedge v. Shawmut Design & Construction Group Long Term Disability Insurance Plan

This case involves Plaintiff William Wedge's challenge under ERISA against the Shawmut Plan and Reliance Standard Life Insurance Company (RSLI) for the termination of his long-term disability benefits. Wedge, a former Senior Project Manager, suffered from Central Serous Chorioretinopathy (CSCR) and had his benefits denied by RSLI, which determined he was not "Totally Disabled" under the "Any Occupation" clause. The court applied an arbitrary and capricious standard of review, considering RSLI's structural conflict of interest but finding it warranted minimal weight. Ultimately, the court concluded that RSLI's decision, supported by comprehensive medical and vocational evidence, including an Independent Medical Examination, was reasonable and not arbitrary or capricious. Therefore, Plaintiff's motion for summary judgment was denied, and Defendants' motion was granted.

ERISA LitigationLong Term DisabilityBenefits DenialArbitrary and Capricious ReviewSummary Judgment MotionDiscretionary AuthorityConflict of InterestCentral Serous ChorioretinopathyMedical EvidenceVocational Assessment
References
46
Case No. MISSING
Regular Panel Decision

In re Robert Plan Corp.

Kenneth Kirschenbaum, the Chapter 7 Trustee for The Robert Plan Corporation and The Robert Plan of New York Corporation, sought court approval for fee awards for himself and his professionals for administering an ERISA plan. The U.S. Department of Labor (DOL) objected, asserting the court lacked jurisdiction to award fees from Plan assets and had specific objections to the reasonableness of the fees. The court affirmed its core jurisdiction over the Trustee's actions as Plan administrator and his professionals' compensation, regardless of whether payments came from Plan or estate assets, citing previous rulings. The court analyzed whether Bankruptcy Code §§ 326 and 330 conflicted with ERISA statutes concerning fiduciary compensation, concluding no substantive conflict existed and the Bankruptcy Code's specific compensation scheme governed. Ultimately, the court largely overruled DOL's objections and granted the fee applications for the Trustee, K & K, Witz, and Whitfield, deeming the requested amounts reasonable and compliant with the Bankruptcy Code. The awards are payable from the Plan's Pguy Account, with any shortfall covered by the Debtors' estate.

Bankruptcy LawERISAChapter 7 TrusteeFee ApplicationPlan AdministrationJurisdictionReasonable CompensationStatutory ConstructionDepartment of LaborFiduciary Duties
References
50
Case No. MISSING
Regular Panel Decision

Pig Newton, Inc. v. Boards of Directors of the Motion Picture Industry Pension Plan

Plaintiff Pig Newton, Inc. commenced an action against the Boards of Directors of the Motion Picture Industry Pension Plan, Health Plan, and Individual Account Plan, seeking a declaration that certain provisions of the Plans’ Trust Agreements were invalid and unenforceable. The Defendants counterclaimed for delinquent contributions under ERISA. The core dispute revolved around "Controlling Employee Provisions" in the Trust Agreements, which obligated employers to contribute for Controlling Employees for a specified number of hours and weeks regardless of actual hours worked. Pig Newton argued these provisions were invalid, not properly incorporated, or conflicted with collective bargaining agreements (CBAs). The Court, applying federal common law and an arbitrary and capricious standard of review for the Directors' interpretation, found the provisions valid, properly incorporated, and not in conflict with the CBAs, concluding that Szekely (Pig Newton's sole owner) qualified as a Controlling Employee. Consequently, the Court denied Plaintiff's motion for summary judgment and granted Defendants' cross-motion for summary judgment, dismissing Plaintiff's complaint and awarding Defendants the sought-after contributions, interest, auditors’ fees, and liquidated damages.

ERISAMultiemployer PlanPension PlanHealth PlanDeclaratory JudgmentSummary JudgmentTrust AgreementsCollective Bargaining AgreementsControlling Employee ProvisionsDelinquent Contributions
References
44
Case No. MISSING
Regular Panel Decision

Medoy v. Warnaco Employees' Long Term Disability Insurance Plan

Plaintiff, Audrey Medoy, sued Warnaco Employees’ Long Term Disability Insurance Plan and Warnaco, Inc. (Defendants) under ERISA, alleging wrongful termination of disability benefits, failure to provide requested documents, and failure to retain claims records. Medoy's disability benefits were discontinued in 1987 without notice. After years of requesting information and appealing the decision, which was hampered by the destruction of her claims file, she filed this action in 1997. Defendants moved to dismiss the complaint, arguing that the claims were untimely, that Medoy was not a 'participant' entitled to disclosure, and that ERISA § 1027 did not cover claims records. The court denied Defendants' motion to dismiss on all grounds, finding her claims timely, her status as a 'participant' colorable, and claims records subject to retention under ERISA § 1027.

ERISALong-term Disability BenefitsStatute of LimitationsFailure to DiscloseRecord RetentionFutility ExceptionAccrual of ActionPlan Administrator DutiesParticipant StatusMotion to Dismiss
References
37
Case No. MISSING
Regular Panel Decision

WEOK Broadcasting Corp. v. Planning Board

The respondent Planning Board of the Town of Lloyd denied WEOK Broadcasting Corporation's application for site plan approval for a radio transmitter facility, citing aesthetic concerns despite a comprehensive Environmental Impact Statement (EIS) and mitigation efforts. The Supreme Court and Appellate Division annulled the Board's decision. The Court of Appeals affirmed these rulings, concluding that the Board's determination lacked substantial evidence, as it relied on generalized community objections rather than factual data to refute WEOK's detailed visual impact analysis. The court emphasized that while aesthetic considerations are valid, decisions must be supported by reasoned elaboration and evidence.

Site Plan ApprovalEnvironmental Impact StatementSEQRA ReviewZoning OrdinanceVisual ImpactRadio TransmitterAesthetic ConsiderationsSubstantial EvidenceAdministrative ReviewArticle 78 Proceeding
References
16
Case No. MISSING
Regular Panel Decision

Mundo v. Sanus Health Plan of Greater New York

Evelyn A. Mundo, a former employee of Sanus Health Plan, was discharged in 1993 and alleged her termination violated the Americans with Disabilities Act (ADA) because Sanus perceived her inability to tolerate stress as an impairment that substantially limited her ability to work. Sanus moved to dismiss the complaint, arguing that job-related stress is not a disability under the ADA. The court granted Sanus' motion, ruling that an inability to tolerate stressful situations is not an impairment for ADA purposes. Furthermore, Mundo failed to demonstrate that her employer considered her generally unable to work in a broad range of positions, rather than just a specific supervisory role. Consequently, the complaint was dismissed in its entirety, and the court declined to exercise supplemental jurisdiction over any remaining state law claims.

ADADisability DiscriminationPerceived DisabilityJob-Related StressMotion to DismissFederal Rule of Civil Procedure 12(b)(6)Major Life ActivityWorkingAmericans with Disabilities ActRehabilitation Act
References
26
Case No. MISSING
Regular Panel Decision

Laflamme v. Carpenters Local 370 Pension Plan

Plaintiff Michael LaFlamme initiated a class action against the Carpenters Local #370 Pension Plan and its Board of Trustees, alleging violations of the Employee Retirement Income Security Act (ERISA) concerning the plan's 'freezing rule' for benefit accrual after a 'break in service.' LaFlamme sought a judicial declaration that this rule contravenes ERISA's minimum accrual standards, along with a reformation of the pension plan and recalculation of benefits for all affected class members. The court, presided over by District Judge Hurd, evaluated the motion for class certification under Federal Rule of Civil Procedure 23(a) and (b), finding that the requirements of numerosity, commonality, typicality, and adequacy of representation were met. Consequently, the motion for class certification was granted, establishing a class comprised of all plan participants, active or retired, who experienced a service break resulting in frozen benefit accrual rates. The decision also outlined procedures for providing notice to the newly certified class members, while deferring detailed adjudication of defenses like statute of limitations and exhaustion of remedies to later dispositive motions.

ERISAPension BenefitsClass ActionBenefit AccrualFreezing RuleBreaks in ServiceClass CertificationRule 23(a)Rule 23(b)Federal Civil Procedure
References
49
Case No. 02 Civ.0032 VM
Regular Panel Decision
Jan 21, 2004

Campanella v. MASON TENDERS'DIST. COUNCIL PENSION

The Campanella brothers, retired participants, sued the Mason Tenders' District Council Pension Plan and its Board of Trustees, alleging multiple ERISA violations regarding pension benefit accrual, vesting standards, and credit for workers' compensation. They challenged the Plan's accrual ranges, anti-backloading provisions, and the policy regarding service credit during disability. The defendants filed cross-motions for summary judgment. The court denied the plaintiffs' motion and granted the defendants' motion, finding that the Plan adhered to ERISA requirements on all substantive points, including minimum accrual standards and vesting. Additionally, claims for interest on delayed benefits and penalties against the Trustees for document production were denied, with the court concluding that no unreasonable delay or bad faith was demonstrated.

ERISAPension BenefitsDisability PensionAccrued BenefitsVesting StandardsStatute of LimitationsSummary JudgmentWorkers' CompensationFiduciary DutyPlan Administration
References
38
Case No. MISSING
Regular Panel Decision

Pagan v. NYNEX Pension Plan

Plaintiff, an employee of NYNEX Corporation and covered by the NYNEX Pension Plan, sought disability pension benefits after an allergic reaction to tobacco smoke. The plan determined she could return to work before completing the required 52 weeks of disability, denying her a pension. Although plaintiff received favorable rulings from state workers' compensation and Social Security, the court ruled that ERISA plans are not bound by these external determinations, emphasizing ERISA's preemption over state law regarding benefit eligibility. The court found the plan's procedures impartial and its interpretation of terms and disclosures sufficient. Consequently, the plaintiff's motions were denied, and the defendants' motion for summary judgment dismissing the complaint was granted.

ERISAPension PlanDisability BenefitsWorkers' CompensationSocial SecuritySummary JudgmentArbitrary and CapriciousPlan InterpretationMedical ReviewBenefit Eligibility
References
12
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