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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
May 26, 2000

Snyder v. Barnhart

Sharon Snyder applied for Supplemental Security Income disability benefits due to severe back pain and carpal tunnel syndrome, which was denied by the Commissioner of Social Security. The Administrative Law Judge (ALJ) found Snyder capable of "medium" work, but not her past work as a maid, and deemed her ineligible for benefits. This decision was affirmed by the Appeals Council. On appeal, the Court found the ALJ erred by not waiting for a detailed response from Snyder's treating physician, Dr. Richard Dobson, regarding her condition and Spinoscope test results, thus failing to fully develop the record. The case is remanded for the ALJ to consider this additional medical information, carefully weigh the treating physician's opinion, reassess Snyder's residual functional capacity (RFC), and re-evaluate her credibility concerning subjective complaints of pain.

Social Security DisabilityChronic Back PainCarpal Tunnel SyndromeSpinoscope TestAdministrative Law JudgeResidual Functional CapacityTreating Physician RuleCredibility AssessmentRemandMedical Evidence
References
12
Case No. MISSING
Regular Panel Decision

Alvarez v. Snyder

This case involves an appeal by plaintiffs from a Supreme Court order dismissing their civil rights complaint, brought under 42 USC § 1983. The plaintiffs, pretrial detainees and their mothers, sought damages for alleged constitutional violations, including infringements on freedom of association and speech, and deprivation of liberty without due process, stemming from 'lock down' orders issued by Justice Leslie Snyder. Justice Snyder, presiding over the detainees' criminal trials, appointed social worker Hillel Bodek as a special master, whose actions were also challenged. The lower court dismissed the complaint based on judicial and quasi-judicial immunity. The appellate court affirmed the dismissal, holding that both Justice Snyder and Bodek were protected by absolute immunity, as their actions were performed within judicial capacity and supported by the court's inherent power to ensure the integrity of its proceedings.

Judicial ImmunityCivil Rights42 USC 1983Pretrial DetaineesFreedom of AssociationFreedom of SpeechDue ProcessSpecial MasterAbsolute ImmunityQuasi-judicial Immunity
References
33
Case No. 2019 NY Slip Op 06521 [175 AD3d 1331]
Regular Panel Decision
Sep 11, 2019

People v. Snyder

The defendant, Crystal Snyder, appealed an order from the Supreme Court, Queens County, which designated her a level two sex offender under the Sex Offender Registration Act (SORA). Snyder, who had pleaded guilty to federal sex trafficking conspiracy, argued for a downward departure to a level one designation, contending she was a victim herself of the commercial sex trade. The Appellate Division, Second Department, found that the circumstances of her exploitation as a minor and her limited management role, without evidence of recruiting or coercing victims, constituted a mitigating factor not adequately considered by the SORA Guidelines. Consequently, the court reversed the Supreme Court's order, granting Snyder's application for a downward departure and designating her a level one sex offender.

Sex Offender Registration ActSORADownward DepartureRisk LevelSex Trafficking ConspiracyVictim ExploitationAppellate ReviewMitigating FactorsFederal ConvictionPresumptive Risk Category
References
6
Case No. MISSING
Regular Panel Decision

Claim of Bishop v. St. Joe Minerals

The claimant, who worked in lead mines for St. Joe Minerals, filed a workers’ compensation claim in 1943 for silicosis, initially found to be a partial disability. After returning to work, his treating physician reported total disablement in 1978, prompting the claimant to reopen his silicosis claim. The Workers’ Compensation Board determined the claim was timely, refused to shift liability to the Special Fund, and found the claimant became permanently disabled from silicosis on September 13, 1976. The employer appealed, contending the claim was barred by Workers’ Compensation Law § 123 and that liability should have been shifted to the Special Fund under Workers’ Compensation Law § 25-a. The appellate court affirmed the Board's decisions, ruling that the Board's determination of the disablement date was a factual question supported by substantial evidence and that the seven-year limitation period commenced from this date, making the reopening timely and precluding the shifting of liability.

SilicosisOccupational DiseaseTotal DisabilityPartial DisabilityReopened CasesStatute of LimitationsDate of DisablementSpecial FundAppellate ReviewMedical Report
References
6
Case No. 2024 NY Slip Op 04584 [232 AD3d 209]
Regular Panel Decision
Sep 25, 2024

Snyder v. AFCO Avports Mgt., LLC

This case concerns a trip-and-fall accident at Stewart International Airport, where plaintiff Kathy Snyder sustained injuries due to an alleged sidewalk defect. Defendants AFCO Avports Management, LLC, and Port Authority of New York & New Jersey moved for summary judgment, asserting the defect was trivial as a matter of law. The Appellate Division, Second Department, addressed key questions regarding the requirement of objective measurements for triviality, the examination of photographic evidence, and the admissibility of human factors expert opinions lacking such measurements. The court held that objective measurements are not a per se requirement, but defendants in this instance failed to meet their prima facie burden. The human factors expert's opinion was deemed conclusory and speculative due to the absence of objective measurements or a reasonably inferable estimate of the defect. Consequently, the lower court's order granting summary judgment to the defendants was reversed, and the motion was denied.

Trip and fallSidewalk defectSummary judgment appealTrivial defect doctrinePhotographic evidenceObjective measurementsHuman factors expert testimonyExpert opinion admissibilityPrima facie burdenAppellate review
References
35
Case No. MISSING
Regular Panel Decision

CBS Inc. v. Snyder

Petitioners CBS, Inc. and two managerial employees sought to stay labor arbitration initiated by James "Jimmy the Greek" Snyder, following his 1988 employment termination. Snyder had pursued arbitration under a collective bargaining agreement with the American Federation of Television and Radio Artists (AFTRA). AFTRA moved to intervene in the court action, primarily to ensure that an arbitrator, not the court, would determine if Snyder's claims were time-barred. The court found that AFTRA possessed a legally protectible interest in the interpretation and enforceability of the arbitration provisions within the National Code, and its interests were not adequately represented by the existing parties. Consequently, AFTRA's motion to intervene as of right was granted.

ArbitrationLabor LawCollective Bargaining AgreementInterventionFederal Rules of Civil ProcedureTimeliness of ClaimsStatute of LimitationsEmployment DisputeUnion RepresentationContract Interpretation
References
5
Case No. ADJ3937063 (AHM 0137186)
Regular
Feb 03, 2012

ERIC BENNETT vs. TRADER JOE'S, ACE AMERICAN INSURANCE, GALLAGHER BASSETT

This case concerns Trader Joe's unreasonable delay in paying a stipulated workers' compensation award by improperly deducting attorney's fees. The Appeals Board denied Trader Joe's Petition for Reconsideration, upholding penalties and attorney's fees for the delay. Furthermore, the Board initiated sanctions against Trader Joe's and its attorneys for filing a petition deemed misleading and without merit. Sanctions will be imposed unless good cause is shown within 15 days.

Stipulated Awardunreasonable delaypermanent disabilityattorney's feesLabor Code section 5814attorney's fees under Labor Code section 5814.5attorney costs under Labor Code section 5811bad-faith actionsfrivolous tacticsmisleading petition
References
0
Case No. ADJ6798245 ADJ6864349
Regular
Jan 05, 2010

Jerry Weissberger vs. TRADER JOE'S

Trader Joe's petitioned for removal to litigate post-termination and statute of limitations issues before the completion of the AME/QME process. The Appeals Board denied the petition, adopting the WCJ's reasoning that Trader Joe's failed to demonstrate substantial prejudice or irreparable harm. The Board found that the defendant's petition lacked sufficient allegations regarding termination notice and that further medical evidence was warranted to determine injury dates and potential exceptions. Therefore, the defendant's petition for removal was denied.

Petition for RemovalOrder Taking Off CalendarMandatory Settlement ConferenceAME/QME processthreshold issuespost terminationstatute of limitationsdue processirreparable harmPanel Qualified Medical Evaluator
References
1
Case No. 2021 NY Slip Op 07264 [202 AD3d 125]
Regular Panel Decision
Dec 22, 2021

Siegel v. Snyder

This case addresses the quality-assurance privilege and the party-statement exception under New York's Education Law and Public Health Law, regarding the discoverability of medical peer-review meeting minutes. The plaintiff sought minutes from a Trauma Peer Review Committee concerning a decedent's treatment, to which defendants asserted privilege. The Appellate Division clarified that the burden lies with the party claiming privilege to prove that unidentified statements in the minutes were made by nonparties, thus ruling that statements with unidentified speakers are discoverable under the party-statement exception. However, the court also determined that references to future corrective actions in the minutes are protected from disclosure. The Supreme Court's order was modified to reflect these findings, affirming the discoverability of unidentified statements while granting a protective order for subsequent corrective action discussions.

Medical MalpracticeQuality Assurance PrivilegePeer ReviewParty Statement ExceptionEducation LawPublic Health LawDiscoveryConfidentialityHospital RecordsUnidentified Speaker
References
42
Case No. ADJ1128865 (VNO 0244369), ADJ1909887 (VNO 0181430)
Regular
Jan 09, 2012

JOE NAVARRO vs. LOCKHEED MARTIN

The Workers' Compensation Appeals Board denied reconsideration of a decision regarding Joe Navarro's claims against Lockheed Martin. The Board adopted the Workers' Compensation Administrative Law Judge's report, which found Navarro to be an unreliable historian with significant symptom magnification. Consequently, the Board denied injury claims for heart and high blood pressure, and upheld a 27% permanent disability award for a psyche injury, based on the judge's credibility findings.

ADJ1128865ADJ1909887plastic parts fabricatorplastic parts fabricator supervisorcontinuous traumapsyche injurypermanent disabilitynon-industrial apportionmentcredible historiansymptom magnification
References
5
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