In the Matter of the Claim of Jeffrey Christie
Claimant Jeffrey Christie, a tour manager for Universal Music Group (doing business as Def Jam Records), sustained injuries in August 2018 when he was assaulted and shot in Missouri. His workers' compensation claim, alleging injury to his right leg and posttraumatic stress disorder, was controverted by the employer and its carrier, who argued he was an independent contractor. A Workers' Compensation Law Judge (WCLJ) found Christie to be an employee and that prima facie medical evidence existed for work-related injuries. The carrier's subsequent application for review by the Workers' Compensation Board was denied for failing to specify an objection to the WCLJ's decision, as required by 12 NYCRR 300.13 (b). The Appellate Division, Third Judicial Department, affirmed the Board's decision, upholding the Board's discretion to deny review for non-compliance, noting that a recently enacted law, Workers' Compensation Law § 23-a, which would provide leniency for application defects, was not yet effective at the time of the carrier's application.