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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

Claim of Pinto v. Southport Correctional Facility

Claimant, a teacher at a maximum-security correctional facility, experienced severe head pains and disorientation, leading to a claim for workers' compensation benefits for work-related stress, depression, headaches, and memory loss. The Workers’ Compensation Board disallowed the claim, finding the presumption of work-related injury rebutted and concluding that the stress experienced was not greater than that usually encountered in his work environment. On appeal, the court affirmed the Board’s decision to deny the claim on the merits. While the court disagreed with the Board's finding that the claim was barred by Workers’ Compensation Law § 2 (7) due to personnel decisions, it upheld the Board's alternate basis for denial, stating that the claimant failed to show the stress was beyond what similarly situated workers experienced.

Workers' CompensationStress-related injuryMental injuryCausationPresumption of injuryRebuttal of presumptionPersonnel decisionWork environmentCorrectional facilityTeacher
References
14
Case No. MISSING
Regular Panel Decision

Claim of Price v. KGM Plastic Industries

Claimant, a sales president for Caprice and KGM Plastic Industries, experienced severe emotional distress due to ongoing conflicts with his superior, Toshimasa Asai, regarding business decisions and job security. This culminated in a heated argument on January 6, 1983, after which the claimant became ill, developed nosebleeds, and suffered a stroke on January 11, 1983, leading to permanent disability. His physician testified that the stroke was causally related to job-induced emotional stress exacerbating pre-existing hypertension. The Workers' Compensation Board found a causally related disability, and this decision was affirmed on appeal, supported by substantial medical evidence despite controverting opinions.

Work-related disabilityEmotional distressCerebral vascular accidentStrokeHypertension exacerbationCausationWorkers' Compensation LawAppellate reviewSubstantial evidenceEmployer-employee conflict
References
3
Case No. MISSING
Regular Panel Decision

Claim of Bottieri v. Travelers Insurance

Claimant, a senior benefits specialist, developed physical and psychiatric symptoms due to perceived job-related stress from early 1990, including headaches, neck/arm pain, "auras," and a seizure. Despite the stress, she sought and received a promotion in 1992, followed by a demotion in 1993, after which she stopped working and filed for workers' compensation benefits in November 1993. A Workers’ Compensation Law Judge initially found the claim compensable, but the Workers’ Compensation Board reversed, concluding that claimant was not exposed to undue job-related stress and that personnel decisions were lawful. On appeal, the court determined that the claim was not barred by Workers’ Compensation Law § 2 (7) as the symptoms predated the personnel decisions. However, the court affirmed the Board’s denial of benefits, finding substantial evidence that the claimant failed to demonstrate her experienced stress was greater than that of similarly situated workers in a normal work environment.

Workers’ CompensationJob StressAccidental InjuryPersonnel DecisionsPromotionDemotionMental InjuryPhysical SymptomsUndue StressNormal Work Environment
References
11
Case No. MISSING
Regular Panel Decision

Cooley v. New York State Police

In January 1985, a State Trooper experienced a heart attack, leading him to file a workers' compensation claim asserting work stress and wood-cutting for fitness as causes. The State Insurance Fund controverted the claim, arguing the heart attack was due to wood-cutting for a personal second job. Initially, a Workers' Compensation Law Judge found occupational disease and awarded benefits, but the Workers' Compensation Board later rescinded this decision, determining that the claimant was not under undue work stress and his heart attack stemmed from personal activity. This appeal affirmed the Board's disallowance, citing substantial evidence that the personal wood-cutting precipitated the heart attack, rather than work-related stress. The court found medical evidence of job-related causation speculative and upheld the Board's resolution of conflicting medical opinions.

Heart AttackOccupational DiseaseJob StressPersonal ActivityCausal RelationshipMedical OpinionSubstantial EvidenceAppellate ReviewWorkers' Compensation BoardClaim Disallowance
References
7
Case No. MISSING
Regular Panel Decision

Claim of Myers v. Eldor Contracting Co.

The case involves an appeal from a Workers’ Compensation Board decision denying death benefits to the claimant, whose decedent, an electrical contractor foreman, suffered a fatal heart attack at work. The Board concluded the death was unrelated to employment, despite claimant's experts linking the heart attack to work-related stress, contingent on reported stress levels. The employer's expert found no relation. The Board found insufficient evidence of work-related stress, discrediting claimant's testimony due to a lack of corroboration and conflicting testimony from employer representatives who described the job as less stressful. The appellate court affirmed the Board’s decision, upholding its authority to resolve factual issues based on witness credibility and its finding that the presumption of compensability was rebutted by substantial evidence.

Heart AttackWork-Related StressCausal RelationshipWorkers' Compensation BoardAppealCredibility of WitnessesPresumption of CompensabilityDeath BenefitsCoronary Artery Disease
References
3
Case No. MISSING
Regular Panel Decision

New York Typographical Union No. 6 v. AA Job Printing

The case concerns a petition by New York Typographical Union No. 6 to confirm arbitration awards against employers AA Job Printing Corp. and The Jewish Press, Inc., for violations of a collective bargaining agreement. The employers cross-moved for summary judgment to dismiss the petition, arguing the awards were not final and that a pending National Labor Relations Board (NLRB) matter preempted the action. The court noted the employers' procedural defaults but favored a decision on the merits. District Judge ROBERT L. CARTER ruled that the arbitration awards were final and definite, and the federal court's jurisdiction under Section 301 of the Labor Management Relations Act was independent of the NLRB's jurisdiction. The court also dismissed the employers' unsupported claim of sexual discrimination. Consequently, the court granted summary judgment in favor of the Union, confirming the arbitration awards, and denied the employers' cross-motion.

Arbitration Award ConfirmationCollective Bargaining AgreementLabor Management Relations ActSection 301 LMRASummary JudgmentFederal Court JurisdictionNLRB PreemptionDefault JudgmentProcedural RulesEmployer-Union Dispute
References
7
Case No. MISSING
Regular Panel Decision
Oct 14, 2003

Claim of Berkley v. Irving Trust Co.

In 1984, the claimant, employed at Irving Trust Company, experienced a job-stress-induced psychotic episode, for which workers' compensation benefits were initially established. By 1995, a Workers’ Compensation Law Judge (WCLJ) and the Workers' Compensation Board determined that her disability was no longer causally related. The case was reopened in 2000 after another psychotic episode, which the claimant alleged was causally linked to her prior employment stress. However, in 2003, a WCLJ and the Board found the latest episode was not causally related to her employment and applied Workers’ Compensation Law § 25-a. The Appellate Division affirmed the Board's decision, giving deference to its resolution of conflicting medical expert testimony, which attributed the recent episode to stress from graduate school rather than a remanifestation of the prior work-related breakdown.

psychotic episodecausally related disabilityworkers' compensation benefitsmedical expert testimonycredibility assessmentpersonality disorderstress-induced illnessappellate reviewWorkers’ Compensation Law § 25-aprior employment stress
References
3
Case No. MISSING
Regular Panel Decision

Claim of Incorvia v. Carborundum Insulation Co.

This is an appeal from a Workers’ Compensation Board decision, filed February 21, 1992, and amended October 30, 1992, which found that the claimant sustained an accidental injury due to employment-related stress. The Board concluded that the claimant's emotional problems were caused by the stress of her job, establishing a causal relationship with her employment. The appellate court affirmed this decision, finding substantial evidence in the claimant's testimony regarding her stressful new position and her psychiatrist's opinion that her adjustment disorder was closely linked to work-related stress.

Workers' CompensationAccidental InjuryEmotional ProblemsWork StressAdjustment DisorderCausationSubstantial EvidenceAppellate ReviewAffirmed DecisionPsychiatric Evaluation
References
2
Case No. MISSING
Regular Panel Decision

Claim of Doersam v. Oswego County Department of Social Services

The dissenting opinion by Mikoll, J., with Levine, J., argues to affirm the Workers’ Compensation Board's decision that the claimant's heart attack was work-related. The dissent references a series of cases, including *Matter of Klimas v Trans Caribbean Airways* and *Matter of Masse v Robinson Co.*, establishing that work-related stress, without further physical incident, can constitute an accidental injury. The Board found the claimant's job consistently stressful, with specific incidents increasing this stress, exacerbating preexisting hypertension and worsening blood pressure, leading to a heart attack on November 26, 1982. The dissent contends that substantial evidence supports the Board's determination, citing testimony from the impartial specialist and the employer's medical expert which, despite not ruling out causality, acknowledged the role of stress. The opinion concludes that the Board rationally found that the claimant's demanding work and subsequent cardiac symptoms from a frightening incident caused the heart attack.

Heart AttackWork-Related StressCausalityDissenting OpinionSubstantial EvidenceOccupational InjuryHypertensionCardiac SymptomsBoard DecisionMedical Opinion
References
4
Case No. MISSING
Regular Panel Decision
Apr 27, 1992

Claim of Rock v. Sullivan County Sheriff's Department

This appeal concerns an employer's objection to the Workers' Compensation Board's finding that a correction officer's myocardial infarction was causally related to job-related stress. The decedent experienced significant stress from an investigation into a prisoner's death, physical assaults by inmates, and an investigation into aiding a jail break. His treating physician attributed the infarction partly to these stresses. The court affirmed the Board's decision, citing substantial evidence and noting that pre-existing conditions or conflicting medical expert testimony did not necessitate a different outcome, as such testimony merely created a question of fact for the Board.

Workers' CompensationMyocardial InfarctionJob-Related StressCausal RelationshipCorrection OfficerInmate AssaultBoard FindingsMedical TestimonyPreexisting ConditionsAppellate Review
References
4
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