Leak v. Mungioli
This case concerns an appeal regarding the allocation of litigation costs in a workers' compensation third-party action. The plaintiff, Robin Leak, sued for personal injuries and received workers' compensation benefits from Hicksville Union Free School District, acting as the carrier. After reaching a settlement with the defendants, a dispute arose over amending a consent letter concerning the calculation of legal fees. The Supreme Court initially granted Leak's motion to amend, which would have resulted in a double payment of legal fees. However, the Appellate Division, Second Department, reversed this decision, emphasizing that under Workers' Compensation Law § 29, the carrier's contribution to litigation expenses should be proportionate to the benefit received, thereby denying the plaintiff's proposed amendment.