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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

Ryan v. New York Telephone Co.

Edward C. Ryan was terminated by New York Telephone Company (Telco) for alleged theft, leading to criminal charges and denial of unemployment benefits. While criminal charges were dropped and the unemployment benefits denial was upheld, Ryan sued Telco for false arrest, malicious prosecution, slander, and wrongful discharge. His wife, Darlene Ryan, also claimed related injuries. Special Term denied Telco's summary judgment motion and struck its res judicata and collateral estoppel defenses. This dissenting opinion argues that the administrative finding of Ryan's misconduct should preclude relitigation under res judicata and collateral estoppel, thus the Special Term's order should be reversed and Telco's cross-motion granted.

Res JudicataCollateral EstoppelUnemployment BenefitsWrongful DischargeFalse ArrestMalicious ProsecutionSlanderAdministrative LawAppellate ReviewSummary Judgment
References
8
Case No. 13483/93, 5550/94
Regular Panel Decision

People v. Ryan

This case addresses whether a court has the inherent power to vacate an illegal sentence more than one year after its imposition, particularly when the sentence was procured through the defendant's fraud and misrepresentation of his identity and criminal history. The defendant, initially identified as Robert Ryan, pleaded guilty to felonies in 1994 and was sentenced as a first-time offender. It was subsequently discovered in 1995 that he was a persistent violent felony offender under the name Keith Kittredge with numerous prior convictions. The court examined precedents regarding judicial power to correct errors after statutory time limits. Ultimately, the court concluded that it possesses the inherent authority to vacate the illegally imposed sentences due to the defendant's active fraud and deceit, distinguishing this situation from cases involving passive acceptance of illegal plea bargains. The matter was set for a hearing to determine new sentencing options or allow the defendant to withdraw his guilty pleas.

fraudmisrepresentationillegal sentenceinherent powervacate judgmentpersistent violent felony offenderpredicate felonyCPL 440.40double jeopardyplea bargain
References
11
Case No. CV-25-0250
Regular Panel Decision
Dec 11, 2025

In the Matter of the Claim of Alex Ryan

The claimant, Alex Ryan, with an established workers' compensation claim for a back injury from a 2018 work-related accident, had his indemnity benefits suspended in 2020 due to a failure to demonstrate labor market attachment. His subsequent request to revisit the labor attachment issue was denied, and that decision was affirmed. In 2024, he was classified with a permanent partial disability with a 71% loss of wage-earning capacity, but reinstatement of benefits was denied pending reattachment to the labor market. The Workers' Compensation Board affirmed this denial. The Appellate Division affirmed the Board's decision, clarifying that while Workers' Compensation Law § 15 (3) (w) eliminates the need for ongoing labor market attachment in certain permanent partial disability cases, it still requires attachment at the time of classification. As the claimant presented no proof of reattachment at classification, his benefits could not be reinstated.

Workers' CompensationPermanent Partial DisabilityLabor Market AttachmentIndemnity BenefitsWage-Earning CapacityStatutory InterpretationAdministrative AppealAppellate ReviewReinstatement of BenefitsDisability Benefits
References
6
Case No. G1999077
Regular Panel Decision
May 19, 2022

In the Matter of the Claim of Alex Ryan

The claimant, Alex Ryan, established a workers' compensation claim for a back injury in a 2018 work-related accident. He was found to be temporarily partially disabled and directed to produce evidence of job market search efforts. Instead, he presented a medical report for total disability based on a right hip injury, which was not part of the established claim. Consequently, his benefits were suspended. The Workers' Compensation Board affirmed the decision, finding no new evidence regarding his labor market attachment and ruling that the COVID-19 pandemic executive order was inapplicable as his benefits were suspended prior to it. The appellate court affirmed the Board's determination that claimant remains unattached to the labor market and is not entitled to further benefits.

Workers' CompensationLabor Market AttachmentDisability BenefitsBack InjuryHip InjuryMedical ReportAppellate ReviewWCB DecisionSuspension of BenefitsCOVID-19 Impact
References
2
Case No. 205 AD3d 1255
Regular Panel Decision
May 19, 2022

Matter of Ryan v. City of Albany

Claimant, Alex Ryan, established a workers' compensation claim for a 2018 back injury. A WCLJ initially found him temporarily partially disabled and required proof of labor market attachment. When claimant failed to provide this, offering instead a medical report of total disability due to a hip injury not part of the established claim, his benefits were suspended. The Workers' Compensation Board affirmed the WCLJ's decision, finding no new evidence of labor market attachment and that a subsequent executive order regarding COVID-19 was inapplicable. The Appellate Division, Third Department, affirmed the Board's decision, concluding that substantial evidence supported the finding that claimant remained unattached to the labor market.

Workers' CompensationLabor Market AttachmentDisability BenefitsBenefit SuspensionAdministrative AppealAppellate ReviewBack InjuryHip InjuryMedical ReportCOVID-19 Executive Order
References
2
Case No. 2025 NYSlipOp 06951
Regular Panel Decision
Dec 11, 2025

Matter of Ryan v. City of Albany Water Dept.

Alex Ryan, a claimant with an established workers' compensation claim for a 2018 back injury, appealed a Workers' Compensation Board decision. Previously, his indemnity benefits were suspended due to a voluntary withdrawal from the labor market. Although later classified with a permanent partial disability, his request to reinstate benefits was denied because he failed to demonstrate reattachment to the labor market at the time of classification. The Appellate Division, Third Department, affirmed the Board's decision, holding that Workers' Compensation Law § 15 (3) (w) requires a claimant to show labor market attachment at the time of classification, even for permanent partial disabilities, particularly if there was a prior finding of voluntary withdrawal.

Workers' CompensationVoluntary WithdrawalLabor Market AttachmentPermanent Partial DisabilityIndemnity BenefitsReduced Earning BenefitsJob Search EffortsWorkers' Compensation BoardAppellate ReviewCOVID-19 pandemic
References
6
Case No. 2019 NY Slip Op 01728
Regular Panel Decision
Mar 12, 2019

O'Dwyer v. Law Offs. of Rex E. Zachofsky, PLLC

This case involves a fee-sharing dispute between Ginarte, O'Dwyer, Gonzalez, Gallardo & Winograd, L.L.P. (plaintiff) and The Law Offices of Rex E. Zachofsky, PLLC (defendant) concerning Workers' Compensation cases. The plaintiff moved to compel discovery, and the defendants moved for partial summary judgment on the breach of contract claim. The Supreme Court initially denied both motions. On appeal, the Appellate Division, First Department, modified the order by granting the plaintiff's discovery motion, allowing access to the Workers' Compensation Board's eCase system for referred cases. The court affirmed the denial of partial summary judgment for the defendants, noting that the breach of contract claim could not be resolved as a matter of law due to evidence of the plaintiff's firm's participation. An appeal and cross-appeal from a subsequent order denying reargument were dismissed as nonappealable.

Fee-sharing agreementBreach of contractRules of Professional ConductDiscovery disputeWorkers' Compensation casesAppellate reviewSummary judgmentAttorney responsibilityE-discoveryLegal ethics
References
3
Case No. 2023 NY Slip Op 02162
Regular Panel Decision
Apr 27, 2023

Matter of Ryba v. Russell

Claimant Paul Ryba filed for workers' compensation benefits after falling off a roof while working for Buczkowski Builders LLC, a subcontractor of Ryan E. Russell, doing business as Ryan's Home Improvements (RHI). Neither Buczkowski nor RHI had workers' compensation insurance. A Workers' Compensation Law Judge (WCLJ) found Buczkowski to be the employer but held RHI liable under Workers' Compensation Law § 56 due to lack of insurance. RHI appealed to the Workers' Compensation Board, arguing § 56 was inapplicable to uninsured general contractors. The Board denied RHI's application for review, finding it incomplete for failing to fully answer question 13 on the RB-89 application. The Appellate Division affirmed the Board's decision, concluding that the Board did not abuse its discretion in denying review due to RHI's non-compliance with the application requirements, and thus, the merits of RHI's appeal were not considered.

Uninsured EmployerGeneral Contractor LiabilityAppellate ReviewAdministrative ProcedureProcedural Non-ComplianceApplication for Review DenialStatutory InterpretationThird DepartmentRB-89 ApplicationSubcontractor Liability
References
6
Case No. 535751
Regular Panel Decision
Apr 27, 2023

In the Matter of the Claim of Paul Ryba

Paul Ryba, a claimant, sustained injuries while working on a roof and filed for workers' compensation benefits. An investigation revealed that neither the general contractor, Ryan E. Russell d/b/a Ryan's Home Improvements (RHI), nor the subcontractor, Buczkowski Builders LLC, had workers' compensation insurance. A Workers' Compensation Law Judge (WCLJ) found RHI liable under Workers' Compensation Law § 56 due to the subcontractor's uninsured status. RHI appealed, challenging the applicability of § 56 to uninsured general contractors. The Workers' Compensation Board denied RHI's application for review, citing its failure to fully complete question 13 of the RB-89 application. The Supreme Court, Appellate Division, Third Judicial Department, affirmed the Board's decision, concluding that the Board did not abuse its discretion in denying review based on RHI's procedural non-compliance, noting that Workers' Compensation Law § 23-a, which addresses such defects, was not yet effective.

Workers' Compensation LawUninsured EmployerGeneral Contractor LiabilityAdministrative ReviewAppellate DivisionProcedural ComplianceBoard RulesStatutory InterpretationRB-89 ApplicationSubcontractor
References
5
Case No. ADJ10256108, ADJ10255968, ADJ10256212, ADJ10256223, ADJ10489875
Regular
Sep 23, 2022

JOSEPH RYAN vs. CALIFORNIA DEPARTMENT OF CORRECTIONS, STATE COMPENSATION INSURANCE FUND

The Appeals Board affirmed the finding of permanent and total disability for the applicant, Joseph Ryan, stemming from industrial injuries sustained while employed as a correctional captain. However, the Board remanded the matter for further proceedings to specifically address apportionment of the permanent disability under Labor Code section 4663, considering the Agreed Medical Evaluator's opinion on pre-existing spinal disease. The Board found that the applicant's specific and cumulative trauma injuries to his spine resulted in intertwined disabilities, justifying a combined award, but that Dr. Hasday's apportionment findings require further development and determination at the trial level.

Workers' Compensation Appeals BoardJoseph RyanCalifornia Department of CorrectionsLegally UninsuredState Compensation Insurance FundADJ10256108ADJ10255968ADJ10256212ADJ10256223ADJ10489875
References
12
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