Claim of Valverde v. New York City Department of Housing Preservation & Development
The claimant was injured in a fall while working as a superintendent in a New York City apartment house. The central issue in this appeal was whether the Workers’ Compensation Board erred in finding that the New York City Department of Housing Preservation and Development (HPD) was the claimant's employer, making them responsible for workers' compensation. HPD had successfully initiated a special proceeding to appoint a '7A Administrator' for the premises, who then managed the building and supervised the claimant. Initially, a Workers’ Compensation Law Judge found both the administrator and HPD as employers, but the Board ultimately concluded HPD was the sole employer. The Appellate Division affirmed this decision, finding that the Board had ample basis to conclude HPD utilized the administrator as its agent, thereby qualifying as the claimant’s employer for Workers’ Compensation Law purposes.