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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision
Jun 02, 1997

Claim of Crawford v. New York City Health & Hospital Corp.

This case concerns an appeal from a Workers’ Compensation Board decision regarding a claimant who sustained a finger injury from a hypodermic needle in 1987. After an initial workers' compensation award, the case was reopened in 1993 when the claimant asserted a claim for a consequential posttraumatic neurosis or 'AIDS reaction phobia'. The employer argued that the two-year Statute of Limitations under Workers’ Compensation Law § 28 barred the psychiatric claim. However, the Board rejected this argument and affirmed the Workers’ Compensation Law Judge's decision to address the psychiatric condition. The Appellate Division affirmed the Board's decision, ruling that Section 28 does not bar amendment of a timely claim to include consequential injuries if a relationship exists between the subsequent claim and the initial injury.

Psychiatric Injury ClaimStatute of Limitations Workers' CompConsequential Psychological InjuriesHypodermic Needle InjuryAIDS Reaction PhobiaWorkers' Compensation Board AppealSection 28 BarAmendment of Timely ClaimCausally Related Disability
References
3
Case No. MISSING
Regular Panel Decision

In re Handicapped Child

The Orchard Park Central School District (District) sought a court-ordered subpoena for psychiatric and psychological records of an infant student from the Western New York Children’s Psychiatric Center. The District intended to use these records in an appeal initiated by the student's parents concerning the child's handicapping condition. The parents cross-moved to quash the subpoena, asserting the records were privileged and their consent for release had been withdrawn. Justice Thomas P. Flaherty ruled that no legislative exception existed to abrogate the physician-patient and psychologist-client privileges in this context, especially over parental objection. Consequently, the court denied the District's motion for the subpoena and granted the parents' cross-motion to quash, underscoring the protection of confidential communications in a child's best interests.

Education LawStudent RecordsPsychiatric RecordsPsychological RecordsPrivilegeSubpoena Duces TecumMotion to QuashParental RightsCommittee on HandicappedFair Hearing
References
17
Case No. ADJ9041984 ADJ9040577
Regular
Dec 21, 2018

ISABEL VALENCIA vs. FIFTH AND PACIFIC COMPANIES, HARTFORD CASUALTY INSURANCE COMPANY, BROADSPIRE SERVICES, INC.

This case involves applicant Isabel Valencia's claim for psychiatric injury stemming from a previously stipulated orthopedic injury. The defendant contended the psychiatric injury was not work-related, arguing it was a consequence of the physical injury. The Appeals Board denied reconsideration, affirming that a "compensable consequence" injury, like a psychiatric condition resulting from an industrial orthopedic injury, is industrially related. The Board also found it appropriate to further develop the record regarding applicant's disability, as the current psychiatric condition prevents accurate assessment.

WORKERS' COMPENSATION APPEALS BOARDFIFTH AND PACIFIC COMPANIESHARTFORD CASUALTY INSURANCE COMPANYBROADSPIRE SERVICESINC.ADJ9041984ADJ9040577Findings Award and Orderstipulationpsychiatric injury
References
1
Case No. ADJ2012304 (STK 0213737)
Regular
May 27, 2014

HILARIO GONZALES vs. DIRK LIMAS CORPORATION, STATE COMPENSATION INSURANCE FUND

This case involved an applicant seeking reconsideration of a Workers' Compensation Judge's decision that denied his psychiatric injury claim due to insufficient employment duration and labeled his accident as not "sudden and extraordinary." The Appeals Board granted reconsideration, finding the psychiatric injury claim compensable because the applicant's testimony, uncontradicted by the defense, established the accident as a sudden and extraordinary employment condition. The Board also ruled the psychiatric expert's reports admissible and remanded the case for further proceedings on permanent disability and future medical care, particularly concerning cognitive and psychiatric conditions. The issue of apportionment of permanent disability was deferred pending further development of the record.

Labor Code section 3208.3(d)sudden and extraordinary employment conditionpsychiatric injurypermanent disabilityfuture medical carereconsiderationvocational expertApportionmentPQMEAME
References
12
Case No. ADJ1936437 (RIV 0070095) ADJ211616 (RIV 0073390)
Regular
Jun 20, 2011

ROSE MARIE RODRIGUEZ vs. HI-DESERT MEMORIAL, ALPHA FUND

In this case, the Workers' Compensation Appeals Board (WCAB) denied reconsideration of a supplemental award. The WCAB affirmed the finding that lien claimants were entitled to reimbursement for psychiatric treatment provided to the applicant. This treatment was deemed a compensable consequence of the applicant's industrial left thumb injury, with medical experts opining the psychiatric condition was predominantly caused by the orthopedic disability. The WCAB found that the industrial physical injury was the predominant cause of the applicant's psychiatric condition, making the treatment necessary.

Workers' Compensation Appeals BoardRose Marie RodriguezHi-Desert MemorialAlpha Fundlicensed vocational nurseorthopedic injurypsyche injurycompensable consequenceLabor Code section 3208.3(b)(1)psychiatric treatment
References
6
Case No. AHM 095279
Regular
Jul 10, 2007

PATRICIA L. THOMPSON vs. ACOSTA SALES AND MARKETING, ROYAL & SUN ALLIANCE

The Appeals Board reversed the WCJ's finding that the applicant's psychiatric injury was barred by Labor Code section 3208.3(d), determining it resulted from a "sudden and extraordinary employment condition" (a severe car accident). However, they affirmed the WCJ's award of medical treatment for the psychiatric condition, as it was deemed necessary to cure or relieve the effects of the applicant's orthopedic injuries sustained in the same incident. The Board concluded that psychiatric treatment was reasonably required for the industrial orthopedic injuries, particularly due to a chronic pain disorder.

Workers' Compensation Appeals Boardpsychiatric injuryLabor Code section 3208.3(d)sudden and extraordinary employment conditionorthopedic injuriesAgreed Medical Examiner (AME)post-traumatic stress disorderpain disordersequelaeindustrial basis
References
7
Case No. ADJ10275361
Regular
Jan 27, 2020

RUSSELL MCFADDEN (deceased); RENEE MCFADDEN, JAZMINE MCFADDEN, and RUSSELL MCFADDEN, II vs. KEOLIS TRANSIT AMERICA; LIBERTY MUTUAL INSURANCE COMPANY

The Workers' Compensation Appeals Board affirmed a judge's decision denying a death benefit claim for Russell McFadden, who died by suicide. The applicant contended his death resulted from an industrial psychiatric injury due to occupational stress. Medical evidence indicated that industrial factors were only a 35% cause of the decedent's psychiatric disorder, with significant pre-existing conditions and drug use being the predominant causes. Furthermore, the Board found no evidence that the suicide was an irresistible impulse, distinguishing it from cases where an industrial injury directly causes a mental condition that prevents resistance to suicide. Therefore, the claim was denied based on the psychiatric injury not being predominantly industrially caused and the suicide not meeting the criteria for compensability.

Workers Compensation Appeals BoardRenee McFaddenKeolis Transit AmericaLiberty Mutual Insurance CompanyADJ10275361Opinion and Decision After ReconsiderationIndustrial Psychiatric InjuryOccupational Stress and StrainCompensable Death ClaimLabor Code Section 3600(a)(6)
References
6
Case No. MISSING
Regular Panel Decision

Claim of Ransiear v. Lewis County Welfare Department

The claimant, a head maintenance man for Lewis County Welfare Department, sustained two independent accidents in September 1962, injuring his left arm, shoulder, and neck, and subsequently developed a psychiatric condition. His employment was terminated shortly after the accidents. The Workmen’s Compensation Board found both physical and mental disabilities causally related to the accidents. Lewis County and its Welfare Department appealed these decisions, arguing a lack of substantial evidence. The court affirmed the board's findings, noting that conflicting medical testimony regarding physical injuries presented a question of fact for the board, and the psychiatric evidence, including an impartial psychiatrist's report, sufficiently supported the causal relationship between the accidents and the psychiatric condition.

Workers' CompensationCausationPsychiatric DisabilityPhysical InjuryMedical Expert TestimonyAppeal DecisionBoard FindingsSubstantial Evidence StandardEmployment-Related InjurySprained Shoulder
References
5
Case No. MISSING
Regular Panel Decision

In re Michael RR.

Petitioner appealed a judgment which denied its application to continue retaining respondent, an individual previously found not responsible for murder by reason of mental disease, at an unsecure psychiatric facility, and instead directed his release under certain conditions. The respondent had been transferred to a nonsecure facility (Capital District Psychiatric Center) after an initial commitment to a secure facility in 1984. A jury in February 2001 found respondent still suffered from a mental illness but concluded that continued inpatient care was not essential. This Court affirmed the judgment, determining that the jury's verdict was not against the weight of the evidence, particularly given the 11-year gap since respondent's last violent acts and evidence suggesting confinement exacerbated his condition. The affirmance ensures respondent's release will be subject to court-ordered conditions including mandatory outpatient mental health treatment, medication compliance, approved housing, and prohibitions on substance abuse and firearms.

Mental IllnessDangerous Mental DisorderInvoluntary CommitmentPsychiatric TreatmentPatient Release ConditionsJury Verdict DeferenceWeight of Evidence ReviewCPL 330.20Mental Hygiene LawParanoid Schizophrenia
References
16
Case No. MISSING
Regular Panel Decision

Mott v. Central New York Psychiatric Center

The claimant, a guard at a state-run psychiatric center, suffered a work-related injury and received workers’ compensation benefits. During his disability, he used personal leave time for which he received full wages. The employer sought reimbursement for these advance payments, but the Workers’ Compensation Board denied reimbursement for the personal leave portion. The Appellate Division reversed this decision, differentiating personal leave from sick leave by noting that personal leave could not be accrued or converted, thus not conferring a permanent benefit to the employer or a detriment to the claimant. The court concluded that denying reimbursement would result in the claimant receiving both full wages and compensation for the same period, a disfavored outcome, and therefore, reimbursement should be granted.

ReimbursementAdvance PaymentsPersonal LeaveSick LeaveWorkers' Compensation BenefitsDisabilityEmployer ReimbursementDisproportionate ResultAppellate DivisionNew York
References
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