Matter of Olivier v. New York State Dept. of Corr.
Claimant Racquel C. Olivier, a correction officer, sustained work-related injuries in April 2022. Her employer, the New York State Dept. of Correction, initially paid her full wages, followed by periods where she used accrued time off and received half salary. After returning to work, her attorney filed for counsel fees, while the employer sought reimbursement for wages paid. The Workers' Compensation Law Judge (WCLJ) established the claim, awarded temporary total disability, and approved counsel fees with a significant portion as a lien against the employer's reimbursement. The Workers' Compensation Board affirmed the WCLJ's decision, determining that the initial award increased compensation, thus justifying the counsel fees as a lien under Workers' Compensation Law § 24 (2) (b). The Appellate Division, Third Department, affirmed the Board's decision, without costs.