MatterofThomas-FletchervNewYorkCityDepartmentofCorrections
Chantel Thomas-Fletcher, a correction officer, sought workers' compensation benefits after an injury. Her counsel requested a venue change from New York City to White Plains, which was denied by a Workers' Compensation Law Judge. A $500 penalty was assessed against counsel under Workers' Compensation Law § 114-a (3) (ii). Upon review, the Workers' Compensation Board affirmed the denial and increased the penalty to $750, finding the appeal was based on previously rejected arguments. The Supreme Court, Appellate Division, Third Judicial Department, affirmed the Board's decision, holding that the challenge to the venue denial was not preserved for review. The court further found substantial evidence supported the Board's determination that the venue change request lacked a reasonable basis and that the $750 penalty assessment was not an abuse of discretion.