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.