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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

Claim of Pinkus v. Hod Carmel Kosher Provision Co.

The claimant appealed the disallowance of his claim, asserting that a work-induced argument with his foreman caused emotional stress, leading to arteriosclerotic and hypertensive heart disease and depressive psychosis. The board found that the incident did not constitute an accidental injury under the Workmen’s Compensation Law, determining that the emotional strain was not greater than typical workplace irritations. Furthermore, the board found no causal relationship between the incident and the disabling conditions, relying on the opinions of the employer’s medical experts in heart diseases, neurology, and psychiatry. The decision of the board was affirmed.

emotional stresswork-induced argumentcoronary insufficiencydepressive psychosiscausationaccidental injuryWorkmen's Compensation Lawworkplace irritationmedical expert testimonyappellate review
References
1
Case No. MISSING
Regular Panel Decision
Aug 05, 1983

Claim of Haydel v. Sears

Claimant, a manager at Sears, Roebuck & Company, experienced psychiatric injury attributed to discovering a newspaper clipping about a past robbery conviction in his personnel file. This incident, distinct from prior marital-related anxiety, led to a diagnosis of schizophreniform psychosis by Dr. John M. Myers, requiring hospitalization. The Workers' Compensation Board found the incident to be an accident arising from employment and causally related to the disability, also denying employer reimbursement due to non-compliance with Workers' Compensation Law § 25(4)(c). The appellate court affirmed the Board's decision.

Psychiatric injuryMental injuryPsychic traumaSchizophreniform psychosisWorkers' Compensation LawCourse of employmentCausally related disabilityPersonnel filePrior convictionHarassment
References
3
Case No. MISSING
Regular Panel Decision

Jamco Building Maintenance Corp. v. New York State Division of Human Rights

This CPLR article 78 proceeding concerns a petition to annul a decision by the Division of Human Rights. The Division had previously found that the petitioner discriminated against its employee, Sierra, through reduced work hours, denial of uniforms, and retaliatory termination following an altercation. However, prior hearings by the New York State Department of Labor and Sierra's union had rejected her claims of sexual harassment and retaliation as incredible. Furthermore, a court-appointed psychiatrist diagnosed Sierra with paranoid personality disorder and delusional psychosis regarding her beliefs. The court ultimately concluded that the Division's Commissioner's findings were not supported by substantial evidence and therefore annulled and vacated the decision, denying the administrative complaint and dismissing the proceeding.

Human RightsDiscriminationRetaliationSexual HarassmentAnnulmentAdministrative LawCredibilityParanoid Personality DisorderDelusional PsychosisArticle 78 Proceeding
References
1
Case No. MISSING
Regular Panel Decision

Arden v. Hutch Manufacturing Co.

Plaintiff Ronnie Arden, a truck driver for Hutch Manufacturing Company, appealed the denial of worker's compensation benefits for a permanent mental disability. The disability stemmed from acute psychosis produced by amphetamine use during a long-haul trip in 1986, where he drove for 40 hours without rest. The trial court found that his injury did not arise out of and in the course of his employment, as the amphetamines were self-administered and not required by the employer. The Supreme Court affirmed the trial court's judgment, stating that there was no causal connection between the work conditions and the resulting injury, as the substance was not found in the workplace, supplied by the employer, or explicitly or implicitly required by employment. The Court concluded that the plaintiff failed to rebut the presumption of correctness attached to the trial court's findings.

Worker's CompensationMental DisabilityAmphetamine UsePsychosisArising Out Of EmploymentCourse Of EmploymentCausal ConnectionTruck DriverOverdoseMedical Causation
References
7
Case No. MISSING
Regular Panel Decision
Jun 28, 1977

Jewish Child Care Ass'n v. Faye K.

An authorized agency appealed two Family Court orders that dismissed petitions seeking to terminate the parental rights of Faye K. and Samuel K. The original dismissal by the Family Court was based on a review of records, including conflicting medical evaluations regarding the parents' mental health. While some reports indicated chronic psychosis, others suggested remission or potential suitability for child return. The appellate court reversed these orders, concluding that the initial determination lacked sufficient basis. It mandated a more thorough hearing, including testimony from Drs. Borbely and Robins, to properly ascertain the children's best interests. This decision underscored the principle that the State requires extraordinary circumstances to deprive parents of custody, with the children's best interests as the guiding factor.

Parental Rights TerminationChild WelfareFoster CareMental HealthPsychiatric EvaluationFamily LawAppellate ReviewBest Interests of the ChildNeglect PetitionCustody Dispute
References
2
Case No. 2024 NYSlipOp 01748 [225 AD3d 1100]
Regular Panel Decision
Mar 28, 2024

Matter of Spillers v. Health & Hosp. Corp.

Claimant Mark K. Spillers, a senior rehabilitation counselor, appealed a Workers' Compensation Board decision disallowing his claim for a causally-related psychological injury. Spillers alleged depression, psychosis, and PTSD from a December 2013 verbal assault by a coworker, but he had a prior established claim from 2007 for physical and consequential psychological injuries. The Workers' Compensation Law Judge (WCLJ) disallowed the 2015 claim, finding Spillers' account of the 2013 incident not credible and that the dispute did not amount to a workplace accident. The Workers' Compensation Board affirmed, deferring to the WCLJ's credibility findings. The Appellate Division affirmed the Board's decision, concluding that the December 2013 incident was an ordinary coworker dispute, not an extraordinary workplace accident under the Workers' Compensation Law, and that Spillers was afforded due process.

Workers' CompensationPsychological InjuryWorkplace StressCredibility DeterminationDue ProcessVerbal AssaultCoworker DisputeAppellate ReviewCausationPermanent Partial Disability
References
15
Case No. 534701
Regular Panel Decision
Mar 28, 2024

In the Matter of the Claim of Mark Spillers

Claimant Mark K. Spillers appealed a decision from the Workers' Compensation Board which ruled that he did not sustain a causally-related psychological injury and disallowed his claim for workers' compensation benefits. Spillers, a senior rehabilitation counselor, alleged depression, psychosis, and PTSD due to a verbal assault by a coworker in December 2013. The Workers' Compensation Law Judge (WCLJ) found prima facie medical evidence based on his treating psychiatrist's reports but disallowed the claim, finding Spillers' account of the incident not credible and that the dispute did not constitute a workplace accident. The Board affirmed, deferring to the WCLJ's credibility determinations. The Appellate Division affirmed the Board's decision, concluding that the December 2013 incident was an ordinary dispute among coworkers to which the employer responded appropriately, and it was not so extraordinary as to constitute a workplace accident under the Workers' Compensation Law.

Workers' CompensationPsychological InjuryVerbal AssaultCoworker DisputeCredibility DeterminationDue ProcessWorkplace AccidentCausationPermanent Partial DisabilityDisability Retirement
References
15
Case No. 2021 NY Slip Op 05950
Regular Panel Decision
Nov 03, 2021

Dojce v. 1302 Realty Co., LLC

The plaintiff, Petrika Dojce, was injured by a power saw while working for an employer hired by 1302 Realty Company, LLC's tenant. Dojce sued 1302 Realty, alleging common-law negligence and violations of Labor Law §§ 200 and 241 (6), including negligent supervision, retention, and hiring, and injuries such as psychosis. The Supreme Court of Kings County denied 1302 Realty's motion to strike negligent supervision claims, granted Dojce's cross-motion for summary judgment on a Labor Law § 241 (6) claim, and granted Dojce's motion to strike certain deposition testimony. On appeal, the Appellate Division, Second Department, modified the Supreme Court's order by granting 1302 Realty's motion to strike the negligent supervision, retention, and hiring claims due to lack of evidence. The Appellate Division also denied Dojce's cross-motion for summary judgment as untimely, as it was filed months after the deadline and raised different issues. The Appellate Division affirmed the striking of Francesco Pedulla's deposition testimony as an appropriate remedy for improperly obtained evidence.

Personal InjuryLabor LawSummary JudgmentNegligent SupervisionNegligent HiringNegligent RetentionDeposition TestimonyUntimely MotionIndustrial CodeWorkplace Safety
References
8
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