Matter of Sutphin v. UPS
Wiley Sutphin, a UPS driver, sustained work-related injuries across three separate claims. The Special Fund was held liable for the first two claims, and Liberty Mutual Insurance Corporation (LM) for the third. A WCLJ declined to apportion liability among the claims. LM sought Board review for the third claim, requesting apportionment, but failed to file separate applications for the other two claims as instructed by a Workers' Compensation Board advisory directive. The Board denied LM's application, citing non-compliance. The Appellate Division reversed this decision, finding that the Board's directive requiring separate filings was not explicitly stated on the form, in its instructions, or in the Board's regulations. Consequently, the Board's denial of review constituted an abuse of discretion, and the case was remitted for further proceedings.