Matter of Balbuena v. Rocco & Son Ironwork Inc.
The case involves an appeal by the State Insurance Fund's (SIF) counsel, The Law Offices of Melissa A. Day, PLLC, against a monetary penalty of $1,000 assessed by the Workers' Compensation Board. The Board had imposed the penalty under Workers' Compensation Law § 114-a (3) (ii) for continuing proceedings without reasonable grounds, specifically regarding improper service of the claimant's application for review due to an incorrect address. SIF's counsel argued that the Brooklyn address used was listed in the Board's file and claimant's medical records. The Appellate Division, Third Department, found that substantial evidence did not support the Board's finding that SIF's counsel offered no reasonable basis for attempting service at the Brooklyn address. Consequently, the decision was modified to reverse the penalty against SIF's counsel, and as modified, affirmed.