In the Matter of the Claim of Mariela Holder (Holder (dec'd), Edward)
Claimant Mariela Holder appealed a decision denying workers' compensation death benefits for her husband, a house manager who died from COVID-19 in March 2020. The Workers' Compensation Board reversed a Workers' Compensation Law Judge's finding, ruling that his death was not causally-related to employment due to insufficient evidence of COVID-19 prevalence in his workplace. The Appellate Division affirmed the Board's decision, stating that the claimant failed to demonstrate specific exposure or an elevated risk of exposure constituting an extraordinary event in the work environment. The court found substantial evidence supported the Board's conclusion that the death did not arise out of and in the course of employment, distinguishing it from prior cases.