Claim of Mickelson v. Value Construction
Claimant, a carpenter, sought workers' compensation benefits for a left wrist injury in April 2013. The Workers' Compensation Board initially ruled the claim time-barred but later rescinded that decision, establishing the claim with a disablement date of May 6, 2013, corresponding to the diagnosis of a work-related ligament injury and arthritis. The employer and carrier appealed this decision. The Appellate Division, Third Department, affirmed the Board's finding regarding the timely filing and date of disablement, noting it was supported by substantial evidence, despite the claimant's earlier symptoms. However, the Court found that the Board failed to address a previously raised issue concerning whether the left wrist injury was consequentially related to a 2003 right wrist injury. Consequently, the Court modified the Board's decision by remitting the matter for further proceedings to address this unadjudicated issue.