Angelo v. Chemical
This appeal concerns a Workers’ Compensation Board decision regarding death benefits for the widow of John Angelo, who died from asbestos-related pleural disease. The decedent's occupational disease claim for pleural asbestosis had a disablement date of May 27, 1994. The Workers’ Compensation Law Judge (WCLJ) established the case for causally-related death, set an average weekly wage of $838.46, and awarded maximum benefits of $500 per week, shifting liability to the Special Fund for Reopened Cases. The Special Fund appealed, arguing the lower statutory maximum rate from the 1994 disablement date should apply, not the rate effective at the time of death. The Board upheld the WCLJ's decision, citing Workers’ Compensation Law § 16 (5) (1), which states the increased maximum death benefit rate applies to deaths occurring on or after July 1, 2007. The court affirmed the Board's decision, finding the statutory language unambiguous and rejecting the Special Fund's arguments.