Matter of Rorapaugh v. New Penn Motor Express LLC
Claimant Sally Rorapaugh's spouse died in a work-related motor vehicle accident. She settled a third-party action for $5.9 million net, prompting the workers' compensation carrier to argue its consent was required and to discontinue payments. The Workers' Compensation Board found the carrier's consent unnecessary due to the settlement exceeding benefits and calculated a lien reduction, concluding the carrier owed claimant an additional $113,631.55. On appeal, the Appellate Division affirmed that carrier consent was not needed for the large settlement. However, it reversed the Board's lien reduction calculation, ruling the Board lacked jurisdiction to determine the equitable apportionment of legal expenses, which must be addressed by the court where the third-party action was filed. The case was remitted for further proceedings consistent with this decision.