In the Matter of the Claim of Debra Clifton
Claimant Debra S. Clifton sought a late payment penalty for a workers' compensation settlement and requested counsel fees for her efforts in securing this penalty. A Workers' Compensation Law Judge (WCLJ) imposed a penalty but denied the request for counsel fees, citing an amendment to Workers' Compensation Law § 24. The Workers' Compensation Board (Board) subsequently modified the penalty amount to $12,083.13 but upheld the denial of counsel fees. On appeal, the Supreme Court, Appellate Division, Third Judicial Department, affirmed the Board's decision, citing its precedent in *Matter of Gonzalez v Northeast Parent & Child Socy.* The core issue revolved around the compensability of counsel fees for late payment penalties under the amended Workers' Compensation Law § 24.