In the Matter of the Claim of Percival Webster
Percival Webster, the claimant, sustained a work-related right knee injury in April 2018, leading to a 50% schedule loss of use (SLU) award for his right leg. In March 2020, while working as a correction officer, he incurred a compensable right hip injury. Following conflicting medical evaluations by Dr. John Ioia and Dr. Adam Soyer regarding the SLU attributable to the hip injury, a Workers' Compensation Law Judge (WCLJ) credited Dr. Ioia's testimony and awarded a 50% SLU for the right leg based solely on the hip injury. The employer's carrier appealed, arguing for an offset against the prior knee injury award under Matter of Genduso. However, citing Matter of Johnson, the Workers' Compensation Board affirmed the WCLJ's decision, finding that the claimant sufficiently demonstrated the hip and knee injuries were separate pathologies. The Supreme Court, Appellate Division, Third Judicial Department, affirmed the Board's decision, concluding that Workers' Compensation Law § 15 (7) allows for multiple SLU awards for successive injuries to the same body member if an increased loss of use from the subsequent injury is proven.