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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

Clear Water Psychological Services PC v. American Transit Insurance Co.

Plaintiff Clear Water Psychological Services PC sought no-fault benefits from defendant American Transit Insurance Company. The plaintiff moved for summary judgment, while the defendant cross-moved for a 90-day stay, arguing that the assignor, Oshane Crooks, was acting as an employee at the time of the November 10, 2014 automobile accident, falling under Workers’ Compensation Board jurisdiction. A key issue was the admissibility of an uncertified police accident report (MV-104AN) which suggested the assignor was driving a taxi. The court ruled the uncertified report inadmissible under CPLR 4518 (c) for authentication reasons, despite the officer's personal observations. However, acknowledging the unresolved factual question of the assignor’s employment status and the Workers’ Compensation Board's primary jurisdiction, the court granted the defendant’s motion, staying the action for 90 days for a Workers’ Compensation Law applicability determination.

No-fault benefitsSummary judgmentStay of actionWorkers' CompensationPolice accident reportAdmissibility of evidenceCPLR 4518Vehicle and Traffic LawPrimary jurisdictionEmployment status
References
12
Case No. 2015-455 K C
Regular Panel Decision
Dec 19, 2017

Metro Psychological Servs., P.C. v. Travelers Prop. & Cas. Ins. Co.

This case involves Metro Psychological Services, P.C., as an assignee, seeking first-party no-fault benefits from Travelers Property & Casualty Insurance Company. The defendant moved for summary judgment, arguing the assignor's injuries occurred during employment, which would make workers' compensation benefits applicable. The Civil Court denied the defendant's motion and granted the plaintiff's cross-motion for summary judgment. The Appellate Term reversed this order, concluding there was an unresolved issue as to whether the plaintiff's assignor was acting in the course of employment at the time of the accident. Consequently, the matter was remitted to the Civil Court to be held in abeyance, pending a determination by the Workers' Compensation Board regarding the parties' rights under the Workers' Compensation Law, underscoring the Board's primary jurisdiction in such matters.

No-Fault BenefitsWorkers' Compensation LawPrimary JurisdictionAbeyanceSummary JudgmentAppellate ReviewInsurance DisputeMedical ProviderAssigneeCourse of Employment
References
9
Case No. 2021 NY Slip Op 04626 [197 AD3d 518]
Regular Panel Decision
Aug 04, 2021

D. S. v. Positive Behavior Support Consulting & Psychological Resources, P.C.

This case involves an appeal by the Port Jefferson School District from an order denying its motion to dismiss a personal injury complaint. The infant plaintiff, a special education student, was allegedly injured by a therapist, Vito Silecchia, during a behavioral therapy session. The plaintiffs sued the School District, among others, alleging Silecchia was an employee or agent. The District contended Silecchia was an independent contractor retained through Positive Behavior Support Consulting and Psychological Resources, P.C. The Appellate Division affirmed the Supreme Court's denial of the dismissal motion, stating that the complaint adequately stated a cause of action and that documentary evidence did not conclusively establish an independent contractor relationship, given provisions in the agreement suggesting the District maintained some control over the services.

Personal InjuryRespondeat SuperiorIndependent ContractorMotion to DismissAppellate ReviewVicarious LiabilitySchool District LiabilitySpecial EducationTherapist NegligenceCPLR 3211 (a) (1)
References
25
Case No. M2006-01023-COA-R3-CV
Regular Panel Decision
Mar 16, 2007

Helen L. Bates v. James G. Neeley, Commissioner of The Tennessee Department of Labor and Workforce Development

Helen L. Bates, a former kitchen supervisor at Highland Youth Center, appealed the denial of her unemployment benefits after she resigned due to a severe assault by a resident at work. She experienced significant psychological trauma and was unable to return. The Department of Labor, Appeals Tribunal, and Board of Review denied her claim, which was affirmed by the Chancery Court, stating she lacked 'good cause'. The Court of Appeals reversed the lower court's decision, finding that the assault and subsequent enduring psychological trauma constituted 'good cause' for voluntarily terminating her employment, thus making her eligible for benefits. The court also held that her receipt of Workers' Compensation benefits did not bar her claim for unemployment benefits.

Unemployment BenefitsWorkplace AssaultPsychological TraumaGood Cause TerminationWorkers' CompensationExclusive RemedyAppellate ReviewVoluntary QuittingEligibility for BenefitsTennessee Court of Appeals
References
5
Case No. 231 AD3d 1379
Regular Panel Decision
Oct 24, 2024

Matter of Lewis v. NYC Admin. for Children Servs.

Claimant Monique Lewis, a social worker, filed for workers' compensation benefits after a dog charged at her during a home visit, causing a chest injury and psychological trauma including PTSD. Initially, the employer accepted the chest injury, and a Workers' Compensation Law Judge established the psychological injuries. However, the Workers' Compensation Board subsequently disallowed the psychological claim, ruling that the stress experienced was not greater than that of similarly situated workers. The Appellate Division, Third Department, reversed this decision, clarifying that the 'greater stress' standard does not apply when psychological injuries directly result from a workplace accident involving physical impact. The court remitted the matter to the Board to determine the causal connection between the established workplace accident and the alleged psychological injuries.

Psychological InjuryPost-traumatic Stress DisorderAnxietyAcute Stress DisorderWorkplace AccidentPhysical ImpactCausal ConnectionAppellate ReviewRemittalDog Attack
References
9
Case No. MISSING
Regular Panel Decision

Wolfe v. Sibley Lindsay & Curr Co.

Chief Judge Breitel dissents from the majority opinion, arguing against the expansion of compensable psychic trauma to include instances where the trauma results from events happening to others. He differentiates this from cases where the claimant is directly involved in the traumatic event. Breitel emphasizes that an individual's vulnerability to such trauma is often idiopathic and specific to their psychological makeup, citing the claimant's 'pseudoneurotic schizophrenic with paranoid features.' The dissent warns that an 'open-ended expansion' of compensation benefits for costly psychiatric care could overburden the existing workmen's compensation system. Therefore, Chief Judge Breitel votes to affirm the Appellate Division's order, implicitly disagreeing with the overall reversal.

Psychic TraumaWorkers' CompensationEmotional DistressBystander RecoveryProximate CauseIdiopathic ConditionsAppellate ReviewDissenting OpinionSystem OverburdeningPsychiatric Care Costs
References
10
Case No. MISSING
Regular Panel Decision

Claim of Smith v. Steuben County Highway Department

This case concerns an appeal from a Workers’ Compensation Board decision that ruled a claimant sustained an accidental injury due to sexual discrimination and harassment at work, precipitating an anxiety neurosis disorder. The claimant, a flagger and the only woman on the job, testified to experiencing various forms of harassment from co-workers, including exposure, crude language, obscene gestures, property theft, and food tampering. Both her treating physician and a workers’ compensation physician opined that her psychological impairment was causally related to her employment. The employer contested the finding, arguing a lack of substantial evidence, but the court affirmed the Board’s decision, reiterating that psychological or nervous injury from psychic trauma is compensable, even with individual sensitivity or a pre-existing psychological illness.

sexual harassmentworkplace harassmentanxiety neurosispsychological injuryaccidental injurycausal relationshipworkers' compensationappealaffirmationpre-existing condition
References
6
Case No. MISSING
Regular Panel Decision

In re St. Christopher-Ottillie

This case involves an appeal concerning the adoption of a child whose initial placement with his aunt and uncle was delayed due to "agency mishaps", leading him to form a strong attachment with his foster parents, Maryann G. and Rafael M. The Law Guardian and interveners Carmen P. and Felix P. appealed orders directing and approving the child's adoption by the foster parents. The appellate court found the existing record insufficient, particularly noting the absence of independent expert psychological evidence regarding the child's best interests, especially concerning potential trauma from separation versus the benefits of sibling reunification. Consequently, the court reversed the Family Court's orders and remitted the matter for a new hearing, emphasizing the critical need for independent psychological evaluations to properly assess the child's current psychological state and make a determination that prioritizes his best interests.

Child adoptionfoster caresibling reunificationindependent expert evidencepsychological evaluationchild traumaFamily Court Act Article 10Family Court Act Section 1055-aKings County Family Courtappellate reversal
References
11
Case No. MISSING
Regular Panel Decision

Valley Psychological, P.C. v. Liberty Mutual Insurance

Plaintiff, Valley Psychological, P.C., provided psychological services to a woman involved in a motor vehicle accident, with claims assigned to plaintiff and covered by defendant, Liberty Mutual Insurance. Defendant denied these claims more than 30 days after receipt, leading plaintiff to file a commercial claim. Defendant asserted a provider fraud defense, alleging improper supervision by plaintiff's principal psychologist. Both City Court and County Court dismissed the claim based on the fraud defense, ruling that the untimely denial did not preclude this defense. However, this Court reversed, holding that defendant's untimely denial did preclude the fraud defense, as it pertained to excessive treatment rather than a strict lack of coverage. The matter was remitted to the City Court of the City of Albany to determine the judgment amount in plaintiff's favor.

no-fault insuranceuntimely denialfraud defensemedical services providerpreclusion doctrinelack of coverageexcessive treatmentworkers' compensation schedulescommercial claimappellate review
References
8
Case No. MISSING
Regular Panel Decision

Peters v. New York State Agricultural & Industrial School

Claimant, a child care worker, suffered severe reactive depression following a 'riot' at his workplace. Despite no physical injury, the Workers' Compensation Board found this psychological injury to be an accidental injury arising out of and in the course of his employment, awarding total and partial disability. The Appellate Division affirmed the Board's decision, confirming that psychological injury caused by psychic trauma is compensable under the Workers’ Compensation Law, supported by substantial evidence and prior case law.

psychic traumapsychological injuryreactive depressionaccidental injurytotal disability awardpartial disability awardchild care workerworkplace incidentanxiety disorderemotional distress
References
2
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