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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

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.

Due ProcessEqual ProtectionCivil Rights ActionDisability BenefitsAccident DisabilityAdministrative LawMedical BoardRight to CounselCross-ExaminationAccess to Evidence
References
8
Case No. MISSING
Regular Panel Decision

Quill v. Koppell

This case addresses the constitutionality of New York Penal Law §§ 125.15(3) and 120.30, which criminalize aiding suicide. Physician plaintiffs argue these laws violate the Due Process and Equal Protection Clauses of the Fourteenth Amendment when applied to physicians assisting mentally competent, terminally ill adults seeking to avoid severe suffering. Plaintiffs sought a preliminary injunction against the enforcement of these statutes. Defendants moved for dismissal. The court denied the plaintiffs' motion for preliminary injunction and granted the defendants' motion to dismiss, finding no fundamental liberty interest in physician-assisted suicide under the Due Process Clause and no violation of the Equal Protection Clause. The court reasoned that the state has legitimate interests in preserving life and can distinguish between refusing medical treatment and actively assisting suicide.

Physician-assisted suicideDue Process ClauseEqual Protection ClauseFourteenth AmendmentTerminal illnessRight to diePreliminary injunctionSummary judgmentCriminal statutesNew York Penal Law
References
16
Case No. MISSING
Regular Panel Decision

National Foods, Inc. v. Rubin

Plaintiff National Foods, Inc. ("Hebrew National") filed a civil rights action against Rabbi Rubin, Director of the Kosher Law Enforcement Division of the New York State Department of Agriculture and Markets, under 42 U.S.C. § 1983 and the Fourteenth Amendment. Hebrew National alleged abuse of state investigatory powers, claiming violations of the due process, establishment, free speech, and commerce clauses, seeking damages and injunctive relief. The complaint detailed events including a 1985 inspection, a subsequent altered report, a 1987 fine, public statements by Rubin, and a 1989 subpoena related to Hebrew National's Indianapolis plant. Defendant Rubin moved to dismiss the amended complaint for failure to state a claim, arguing that the allegations amounted to a state tort defamation claim. The court granted Rubin's motion, finding that Hebrew National failed to allege actionable constitutional deprivations under the "reputation-plus" standard for due process claims, presented no facts suggesting a theological dispute for the establishment clause claim, offered conclusory allegations for the free speech claim, and did not demonstrate a substantial burden on interstate commerce for the commerce clause claim.

Civil Rights Action42 U.S.C. § 1983Due Process ClauseFourteenth AmendmentCommerce ClauseEstablishment ClauseFree Speech ClauseMotion to DismissConstitutional LawState Official Liability
References
16
Case No. ADJ3714425 (FRE 0234250) ADJ896033 (FRE 0171714)
Regular
Aug 22, 2014

MICHAEL WRIGHT vs. STAR MEDIA, TRAVELERS INDEMNITY COMPANY OF CONNECTICUT

The Workers' Compensation Appeals Board granted reconsideration, rescinding a WCJ's order that enforced a reimbursement order against Travelers Indemnity Company. The Board found the reimbursement order void *ab initio* due to procedural due process infirmities. Specifically, the "self-destruct" clause in the order did not comport with due process protections outlined in precedent cases like *Mitchell v. Golden Eagle Ins.*, failing to guarantee a review of objections or automatically void the order upon valid objection. Therefore, Travelers' due process rights were violated, necessitating the rescission of the WCJ's findings.

Workers' Compensation Appeals BoardPetition for ReconsiderationOrder for ReimbursementCalifornia Insurance Guarantee Association (CIGA)Cumulative Trauma InjuryAgreed Medical Examiner (AME)ApportionmentDue ProcessSelf-Destruct ClauseVoid Ab Initio
References
2
Case No. No. 616CV0440DNHATB
Regular Panel Decision
Jun 23, 2016

Brooks v. Roberts

Plaintiffs, New York residents receiving Supplemental Nutrition Assistance Program (SNAP) benefits, filed a class action against Samuel D. Roberts, Commissioner of the New York State Office of Temporary and Disability Assistance (OTDA). They challenged the termination of their SNAP benefits, alleging violations of the Fourteenth Amendment's Due Process Clause and federal SNAP Act statutes/regulations due to inadequate and untimely notices regarding the 'Able Bodied Adults Without Dependents' (ABAWD) work rules. The court denied the plaintiffs' motions for class certification and a preliminary injunction, citing a lack of irreparable harm for the latter. It also denied the defendant's motion to dismiss for failure to join a necessary party. However, the court partially granted and partially denied the defendant's motion to dismiss for failure to state a claim, dismissing due process claims related to ABAWD classification but allowing statutory claims and due process claims related to benefit termination to proceed.

Supplemental Nutrition Assistance ProgramSNAP BenefitsFood StampsABAWD Work RulesDue ProcessFourteenth AmendmentClass CertificationPreliminary InjunctionMotion to DismissAdministrative Law
References
106
Case No. MISSING
Regular Panel Decision
Dec 19, 2014

Nawrocki v. New York State Office of Children & Family Services

Jacquelyn Nawrocki, a former employee of the New York State Office of Children and Family Services (CFS), brought an action against CFS and Dr. Sheila Reed, alleging a federal civil rights claim under the Due Process Clause of the Fourteenth Amendment and state-law claims for defamation and emotional distress, following her employment termination in 2013. Defendants moved to dismiss the complaint for failure to state a claim. The court determined that Nawrocki's federal due process claim, based on a 'stigma-plus' theory, failed because the availability of an Article 78 proceeding under New York CPLR provided adequate post-termination due process, regardless of whether she pursued it. Consequently, the federal claim was dismissed. The court then declined to exercise supplemental jurisdiction over her state-law claims.

Federal Civil RightsDue ProcessFourteenth AmendmentStigma-Plus ClaimEmployment TerminationPublic EmployeeNew York State LawCPLR Article 78Supplemental JurisdictionMotion to Dismiss
References
21
Case No. 96
Regular Panel Decision
Oct 24, 2017

American Economy Insurance Company v. State of New York

The New York Court of Appeals examined the constitutionality of a 2013 amendment to Workers' Compensation Law § 25-a, which closed the Special Fund for Reopened Cases to new applications. Plaintiff insurance companies argued this imposed unfunded liabilities for policies finalized before the amendment, violating constitutional clauses. The Appellate Division had found the amendment unconstitutional as retroactively applied. However, the Court of Appeals reversed, concluding that even assuming a retroactive impact, it was constitutionally permissible under the Contract, Takings, and Due Process Clauses. The court found the amendment did not impair contracts, identify a vested property interest, or violate due process, as its retroactive application served a rational legislative purpose to benefit New York businesses.

Workers' CompensationInsurance LawRetroactive LegislationContract ClauseTakings ClauseDue ProcessSpecial Fund for Reopened CasesConstitutional LawLegislative AmendmentPolicy Liability
References
45
Case No. MISSING
Regular Panel Decision

Association of Surrogates & Supreme Court Reporters Within New York v. New York

This case involves eleven plaintiff labor organizations challenging Section 375 of Chapter 190 of the Laws of New York of 1990, which implemented a lag payroll system for nonjudicial employees of the Unified Court System. The plaintiffs argued that this law unconstitutionally impaired their collective bargaining agreements and violated the Contract Clause, Equal Protection, and Due Process clauses of the Fourteenth Amendment. The District Court denied the plaintiffs' motions for preliminary injunction and summary judgment. The court found no contractual impairment, citing a statutory provision requiring legislative action for compensation agreements. It concluded that the lag payroll was a reasonable and necessary measure to address the state's fiscal crisis, and that the statute satisfied the rational basis test for equal protection and due process claims. Consequently, the court granted the defendants' cross-motion for summary judgment.

Lag Payroll SystemContract ImpairmentEqual ProtectionDue ProcessCollective BargainingSummary JudgmentPreliminary InjunctionFiscal PolicyState EmployeesJudicial System
References
11
Case No. 1:12-cv-46
Regular Panel Decision
Sep 24, 2018

Lillian Roberts Dir. of Dist. Council 37, Afscme ex rel. Situated v. Cuomo

Plaintiffs, a group of active and retired New York State employees, sued the State and various officials, alleging that a unilateral increase in health insurance contributions for retirees violated the Contracts Clause and Due Process Clause of the U.S. Constitution, breached their collective bargaining agreements, and violated state law. The defendants moved for summary judgment, arguing that no contractual right to perpetually fixed premium contribution rates existed and that the increase was a reasonable and necessary response to a significant fiscal crisis. The court granted the defendants' motion for summary judgment, finding that the collective bargaining agreements did not establish a vested right to fixed retiree health insurance rates and that the state's actions were a legitimate and necessary measure to address its financial distress. All of plaintiffs' claims, including those for breach of contract, due process violations, and state law violations, were dismissed.

Collective Bargaining AgreementHealth Insurance PremiumsRetiree BenefitsContracts ClauseDue Process ClauseSummary JudgmentFiscal CrisisState EmployeesCivil Service LawProperty Interest
References
81
Case No. MISSING
Regular Panel Decision

Empire Gen Holdings, Inc. v. Governor of New York

The applicants, Empire Gen Holdings, Inc. and Empire Generating Co, LLC, initiated a declaratory judgment and injunction action challenging the constitutionality of New York Tax Law §§ 33 and 34, known as the "Tax Credit Deferral Provisions". They contended that these provisions unconstitutionally delayed their receipt of a significant brownfield redevelopment tax credit, violating their rights under the Takings Clause, Due Process, Contracts Clause, and Equal Protection. The defendants moved to dismiss the complaint for failing to state a cause of action. The court granted the defendants' motion, ruling that the plaintiffs had no vested property right to the tax credit prior to the enactment of the deferral provisions, thereby defeating their Takings and Due Process claims. Furthermore, the court found no contractual impairment and determined that the tax credit classifications were rationally related to legitimate government interests, leading to the dismissal of all constitutional challenges.

Constitutional LawTax LawDeclaratory JudgmentInjunctionTax CreditsBrownfield RedevelopmentTakings ClauseDue ProcessContracts ClauseEqual Protection
References
20
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