Matter of Ferguson v. Eallonardo Constr., Inc.
Stephen Ferguson, a claimant, sustained a work-related right shoulder injury in August 2016. Following a consultant's finding of a 40% schedule loss of use, Ferguson's counsel was notified to obtain a competing medical opinion within 60 days. Counsel's subsequent request to cross-examine the carrier's consultant was denied by the Workers' Compensation Law Judge (WCLJ) and affirmed by the Workers' Compensation Board, which deemed the request untimely and the opportunity waived. The Appellate Division, Third Department, reversed this decision, holding that the request for cross-examination was timely made at the first permanency hearing and was not contingent on filing a competing medical report. The matter was remitted for further proceedings consistent with the court's decision.