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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

Chen v. Major League Baseball

John Chen sued Major League Baseball Properties, Inc. and the Office of the Commissioner of Baseball (MLB) under the FLSA and NYLL, claiming minimum wage violations for his unpaid volunteer work during the 2013 Baseball All Star Game's "FanFest". He sought conditional class certification. MLB moved to dismiss the complaint, arguing that Chen was a volunteer and that FanFest, as a seasonal "amusement or recreational establishment," was exempt from FLSA minimum wage requirements. The court granted MLB's motion to dismiss the FLSA claims, finding that FanFest qualified for the Section 13(a)(3) exemption due to its short operational period and status as a distinct physical place of business. Consequently, Chen's motion for collective certification was denied as moot, and his state-law NYLL claims were dismissed without prejudice.

FLSA ExemptionMinimum Wage ClaimsVolunteer EmploymentSeasonal OperationsDistinct Physical Place of BusinessEnterprise vs EstablishmentClass Action DenialState Law Claims DismissalJudicial DiscretionStatutory Interpretation
References
38
Case No. MISSING
Regular Panel Decision

Garber v. Office of the Commissioner of Baseball

This opinion and order by District Judge Shira A. Scheindlin addresses a motion to certify an interlocutory appeal regarding the "baseball exemption" from antitrust liability. The MLB Defendants, joined by Television Defendants, sought to appeal an earlier ruling from August 8, 2014, which held that the Office of the Commissioner of Major League Baseball was not shielded by the baseball exemption in cases like Laumann v. National Hockey League and Garber v. Major League Baseball. The court denies the motion, finding no substantial ground for difference of opinion on the baseball exemption's applicability, nor would an immediate appeal materially advance the litigation's termination. Furthermore, the court clarifies that the scope of the baseball exemption is a threshold merits issue, not a jurisdictional question.

Interlocutory AppealSummary JudgmentAntitrust LiabilityBaseball ExemptionSherman ActControlling Question of LawSubstantial Ground for Difference of OpinionMaterially Advance LitigationJurisdictional IssueMerits Issue
References
27
Case No. MISSING
Regular Panel Decision

Matter of TCR Sports Broadcasting Holding, LLP v. WN Partner, LLC

This dissenting opinion addresses an arbitration dispute over telecast rights fees between the Baltimore Orioles/MASN and the Washington Nationals, administered by Major League Baseball (MLB). MASN and the Orioles sought to vacate the arbitration award, alleging evident partiality due to conflicts of interest involving the Nationals' law firm, an MLB loan to the Nationals, and MLB's significant influence. While the Supreme Court vacated the award, it remanded the matter to the same arbitral forum (RSDC). The dissent argues that MLB's pervasive bias, financial stake, and the Commissioner's public statements prevent a fundamentally fair rehearing by the RSDC, necessitating referral to a neutral forum like the American Arbitration Association to preserve arbitration integrity.

ArbitrationEvident PartialityContract ReformationJudicial Review of ArbitrationSports LawBaseball IndustryConflict of InterestArbitrator BiasArbitral Forum SelectionDissenting Opinion
References
23
Case No. 0976 2335
Regular Panel Decision
Jan 05, 2011

Claim of Runge v. National League of Baseball

The claimant sustained knee injuries in March 1997. The workers' compensation carrier continued to pay medical expenses until 2002, despite the claim being closed in April 1998. In 2004, the claimant sought to reopen the claim, but a Workers' Compensation Law Judge and the Board found it time-barred under Workers’ Compensation Law § 123. The Appellate Division modified the decision, ruling that the carrier's voluntary payments for causally related medical treatments during the relevant period precluded the application of Workers’ Compensation Law § 123. The case was remitted to the Workers’ Compensation Board for further proceedings.

Time-barred claimsReopened claimsMedical expense reimbursementVoluntary paymentsStatutory barAppellate decisionRemittedKnee injuryWorkers’ Compensation Law § 123Continuing jurisdiction
References
7
Case No. MISSING
Regular Panel Decision
Jan 05, 2011

Claim of Runge v. National Baseball League

The claimant, a major league baseball umpire, allegedly injured his right knee in May 1992. The employer initially paid medical bills but later disputed them and sought relief from the Special Fund for Reopened Cases under Workers’ Compensation Law § 25-a, also arguing the claim was barred by Workers’ Compensation Law § 123. Both the Workers’ Compensation Law Judge (WCLJ) and the Workers’ Compensation Board found WCL § 123 inapplicable, ruling that the case was not truly closed because further medical evidence was contemplated in 1992 and 2005. The Appellate Division affirmed the Board's decision, concluding that the Board's finding was supported by substantial evidence and that WCL § 123 did not bar further proceedings.

Workers' Compensation LawSection 123Section 25-aCase ReopeningStatute of LimitationsMedical EvidenceAppellate ReviewBoard DecisionKnee InjuryClaim Closure
References
5
Case No. 2020 NY Slip Op 01870 [181 AD3d 1116]
Regular Panel Decision
Mar 16, 2020

Matter of Hirschbeck v. Office of the Commr. of Major League Baseball

Claimant Mark Hirschbeck appealed a decision by the Workers' Compensation Board, which denied his application for review of a Workers' Compensation Law Judge's decision. The Board's denial was based on procedural non-compliance, specifically that the claimant failed to properly fill out the RB-89 form by merely referencing the entire Board case file instead of specifying relevant documents. The Appellate Division, Third Department, affirmed the Board's decision, finding no abuse of discretion in denying the application due to the claimant's failure to adhere to prescribed formatting and completion requirements. The court noted that arguments regarding the underlying merits of the WCLJ's decision were not properly before them. This case underscores the importance of strict adherence to procedural rules in workers' compensation appeals.

Workers' Compensation LawAppellate ReviewProcedural ComplianceApplication DenialAdministrative LawBoard ReviewWCLJ DecisionRB-89 FormRegulatory RequirementsClaimant Representation
References
7
Case No. MISSING
Regular Panel Decision

Golden v. Secretary of Health and Human Services

William Golden, a Vietnam veteran, challenged the Secretary of Health and Human Services' denial of disability benefits. Golden asserted disability since November 1980 due to severe Post Traumatic Stress Disorder (PTSD) and back problems, contrary to the Administrative Law Judge's (ALJ) finding of disability commencing November 1985. District Judge Curtin ruled that the ALJ incorrectly applied the treating physician rule by dismissing Dr. Herman Szymanski's retroactive diagnosis as speculative. The court emphasized that a treating physician's long-standing relationship with a patient warrants extra weight for their opinion, which Dr. Szymanski's opinion, supported by other witnesses, demonstrated despite some contradictory medical evidence. Ultimately, the court found the Secretary's denial unsupported by substantial evidence, granted Golden's motion for summary judgment, and remanded the case for benefit calculation.

PTSDDisability BenefitsSocial Security ActTreating Physician RuleRetroactive DiagnosisAdministrative Law JudgeMedical EvidenceVocational RehabilitationMental DisorderBack Pain
References
13
Case No. MISSING
Regular Panel Decision
Jun 18, 2003

Local 8A-28A Welfare and 401 (K) Retirement Funds v. Golden Eagles Architectural Metal Cleaning and Refinishing

The plaintiffs, Local 8A-28A Welfare and 401(k) Retirement Funds, sued defendant Golden Eagles Architectural Metal Cleaning and Refinishing, alleging violations of ERISA Section 515 and a collective bargaining agreement for failing to submit to an audit. Golden Eagles moved to dismiss the complaint, asserting lack of personal jurisdiction, improper venue, and the requirement for arbitration. The District Court, presided over by Judge Sweet, denied the motion, finding that personal jurisdiction existed over Golden Eagles due to ERISA's nationwide service of process provision, and venue was proper in the Southern District of New York as the Funds are administered there. Furthermore, the court determined that the Local 8A-28A Funds, as independent non-signatory entities, were not bound by the arbitration clause present in the collective bargaining agreement between the union and the employer. Consequently, Golden Eagles' motion to dismiss was denied.

ERISAPersonal JurisdictionVenueArbitrationCollective Bargaining AgreementEmployee BenefitsTrust FundsMotion to DismissNationwide Service of ProcessMinimum Contacts
References
26
Case No. MISSING
Regular Panel Decision

Neeld v. American Hockey League

Plaintiff Gregory P. Neeld, a one-eyed individual, sought a preliminary injunction against the American Hockey League (AHL) to challenge its by-law (Article 13(e)) prohibiting one-eyed players from participating in professional hockey. Neeld alleged violations of 42 U.S.C. § 1983 and New York's Human Rights Law § 296(1)(a). The court dismissed the § 1983 claim for lack of state action but found a probability of success on the state human rights claim, noting that visual impairment can only be a bar if it's a bona fide occupational qualification. The court also addressed diversity jurisdiction, dismissing a non-diverse defendant to retain the state claim. Ultimately, the court granted a preliminary injunction, preventing the AHL and its New York franchises from applying Article 13(e) to Neeld within the state.

Disability DiscriminationProfessional HockeyPreliminary InjunctionHuman Rights LawState ActionDiversity JurisdictionOccupational QualificationSports LawIrreparable HarmNew York Law
References
21
Case No. ADJ8314191
Regular
Apr 27, 2015

JUAN MELO vs. THE SAN FRANCISCO GIANTS, ACE AMERICAN INSURANCE COMPANY, THE GOLDEN BASEBALL LEAGUE, STATE COMPENSATION INSURANCE FUND

The Appeals Board granted reconsideration and rescinded a Workers' Compensation Judge's (WCJ) order for reimbursement of costs. The WCJ had ordered the State Compensation Insurance Fund (SCIF) to pay $1,350.00 to applicant's attorney for delays in clarifying insurance coverage. However, the Board clarified that Labor Code section 5811(a) does not permit the award of attorney's fees as costs, and any such award under Labor Code section 5813 would require proper notice and an opportunity to be heard, which was not provided. Therefore, the WCJ's order was improper.

Workers' Compensation Appeals BoardPetition for ReconsiderationOrder for Reimbursement of CostsLabor Code section 5811(a)State Compensation Insurance Fund (SCIF)Coverage issuesContinuous trauma claimInsurance policyRidersPolicy premium
References
4
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