Matter of Kaminski v. Integrated Structures Corp.
Zygmunt Kaminski, a construction worker, sustained catastrophic injuries in 2015, leading to a workers' compensation claim. He was found permanently totally disabled and authorized 24-hour home health care by the Workers' Compensation Board in prior decisions. The employer and carrier later sought to reduce this care, but a Workers' Compensation Law Judge (WCLJ) and subsequently the Board denied their request, applying the doctrine of res judicata (collateral estoppel) as the issue was previously litigated and decided. The Board also found that the carrier failed to demonstrate a material improvement in Kaminski's condition. The Appellate Division, Third Department, affirmed the Board's decision, concurring that the issue of 24-hour home health care was barred from relitigation as it had been fully and fairly decided in prior proceedings from which no appeal was taken.