Matter of Gabel (Bankers Life & Cas. Co.--Commissioner of Labor)
Claimant Christopher M. Gabel, an insurance broker, sought unemployment insurance benefits after his agreement with Bankers Life and Casualty Company (BLC) was terminated. While an Administrative Law Judge initially denied benefits, the Unemployment Insurance Appeal Board reversed, ruling that BLC was liable for contributions. The Board found that Gabel's services were not statutorily exempted under Labor Law § 511 (21) because his actual work was inconsistent with the contract's statutory provisions, and BLC maintained sufficient supervision and control to constitute an employment relationship. BLC appealed, contending its written agreement met the Labor Law requirements and that Gabel was an independent contractor. The Appellate Division, Third Department, affirmed the Board's decision, stating that the actual performance of services must conform to the statutory provisions, not just their inclusion in the contract. The court also found substantial evidence that BLC exercised significant control over Gabel's work, thus establishing an employment relationship.