In the Matter of the Claim of Sally Rorapaugh
The Workers' Compensation Board (Board) found that claimant Sally Rorapaugh was not required to obtain the carrier's consent for settling her third-party action, as the settlement amount of $9 million significantly exceeded her estimated lifetime workers' compensation benefits. The Board also calculated a reduction on the carrier's lien, determining that the carrier owed claimant an additional $113,631.55. On appeal, the Appellate Division, Third Judicial Department, affirmed the Board's finding that carrier consent was unnecessary under Workers' Compensation Law § 29 (5). However, the Court reversed the Board's decision regarding the lien reduction calculation, holding that the Board lacked jurisdiction to determine the equitable apportionment of legal expenses, which must be sought in the court where the third-party action was instituted. Consequently, the matter was remitted to the Board for further proceedings consistent with the Appellate Division's decision.