Claim of Oliva v. Albany Cycle Co.
This case concerns a claimant's appeal from two decisions by the Workers’ Compensation Board, filed May 6, 1977, and June 29, 1978, which had denied his application to reopen and reconsider a referee’s decision from March 25, 1976. The referee had previously denied the claimant’s claim for death benefits for his deceased wife, stating that he failed to establish dependency as required by Workers’ Compensation Law § 16. The claimant sought reopening after Matter of Passante v Walden Print. Co. declared section 16 unconstitutional for its gender-based dependency requirements. However, the Board rejected the application due to an untimely appeal. The court affirmed the Board's decision, concluding that the Board did not abuse its discretion as Passante did not expressly mandate retroactive application.