In the Matter of the Claim of Felipe Zamora Ramales
Claimant Felipe Zamora Ramales, a pizzeria kitchen assistant, suffered severe burns after a fall down basement stairs while carrying a large pot of hot tomato sauce. Emergency notes indicated a high blood alcohol content, leading the employer and carrier to argue his injuries were solely due to intoxication and thus not compensable. Initially, a Workers' Compensation Law Judge disallowed the claim, but the Workers' Compensation Board reversed this, establishing the claim and finding that intoxication was not the sole cause, invoking the presumption of compensability under Workers' Compensation Law § 21 (4). The Appellate Division, Third Judicial Department, affirmed the Board's decision, determining that the carrier failed to meet the heavy burden of proof required to rebut the presumption. The court reasoned that navigating a heavy pot down stairs was a contributory factor in the accident, preventing intoxication from being the exclusive cause.