Matter of Taitt v. Manhattan and Bronx Surface Transit Operating Authority
The claimant, a bus driver residing in the Bronx, filed for workers' compensation benefits after an injury. Her counsel requested a change of venue from Harlem to White Plains, citing the claimant's anxiety due to a prior assault in Harlem and difficulty traveling due to knee and back conditions. A Workers’ Compensation Law Judge (WCLJ) denied the request, referencing a policy that disallows venue changes for public benefit corporations unless the employer is located in the requested district. The WCLJ also imposed a $750 penalty on claimant's counsel for lacking reasonable grounds. The Workers’ Compensation Board affirmed both the denial of the venue change and the penalty. The appellate court affirmed the Board's decision, finding no reasonable basis for the venue change and upholding the penalty, noting counsel's history of similar actions.