Sass v. AMR Electro Conduits, Inc.
Claimant, a tractor-trailer truck driver, was rendered a quadriplegic after an accident on November 20, 1981. His employer, AMR Electro Conduits, Inc., and its insurance carrier, the State Insurance Fund, were notified. The Fund began paying benefits but subsequently filed a notice of controversy, almost eight months past the deadline, alleging newly discovered evidence that the claimant was not an employee of AMR or that the injury did not arise in the course of employment. The Workers’ Compensation Board refused to excuse the late filing, citing Workers’ Compensation Law § 25 (2) (b), which imposes a pleading bar for untimely controversies. The appellate court affirmed the Board's decision, determining that the Fund's evidence was belatedly obtained rather than newly discovered and its failure to investigate earlier was not a valid excuse for the late filing.