Matter of Thompson v. Hayduscko
Claimant Gloria Thompson, a licensed home health aide, was initially employed by M.E.A. Healthcare Services. She was later privately hired by Clare Hayduscko to provide nursing services to Eleanor Adamec, working over 40 hours per week and paid with Adamec's funds. In June 2007, Thompson injured her right ankle while caring for Adamec and filed a workers' compensation claim against Hayduscko, who she named as her employer. A Workers' Compensation Law Judge (WCLJ) twice determined that Thompson was an independent contractor, disallowing the claim. However, the full Workers' Compensation Board reversed, finding Thompson to be a domestic worker engaged in covered employment and Hayduscko to be her employer, establishing the claim for accidental injury. Hayduscko appealed this Board decision. The Appellate Division, Third Department, dismissed the appeal, ruling that the Board's determination of an employer-employee relationship is not a final, appealable order as it does not resolve all substantive issues in the claim and thus does not present a threshold legal issue for review prior to the Board's final determination.