Lowcher v. Beame
Plaintiff, a former school secretary, initiated a civil rights action under 42 U.S.C. § 1983 against the Board of Estimate of the City of New York, the New York Teachers’ Retirement System, and the New York City Employees’ Retirement System. She alleged deprivation of her constitutional rights to due process and equal protection after her application for accident disability benefits was denied. The Medical Board of the New York Teachers’ Retirement System determined her disability was not proximately caused by a 1970 assault, and denied her requests for legal representation, witnesses, and access to a referred physician's report. Defendants moved to dismiss the complaint for failure to state a claim. Judge Metzner denied the motion, ruling that while a full adversarial hearing was not required, the plaintiff was entitled to know the evidence upon which the Retirement System made its determination, implying a due process violation in denying access to the medical report.