Dorosz v. Green & Seifter
The case concerns a workers' compensation claim filed by the widow of an accountant who died from a heart attack while bowling in a league sponsored by a client of his firm. The Workers' Compensation Board denied the claim, ruling that the death did not arise out of employment, as the bowling was a voluntary, off-duty athletic activity. This decision was based on Workers’ Compensation Law § 10, which restricts benefits for such activities unless the employer required participation, compensated the employee, or sponsored the activity. The Appellate Division upheld the Board's determination, and the Court of Appeals affirmed, finding no evidence that the employer met any of the statutory criteria for compensation. The court emphasized that a benefit to the employer alone is not sufficient, and the activity did not constitute part of the employee's work-related duties.