Clark v. New York City Department of Human Resources Administration
Claimant received workers' compensation benefits for work-related injuries and settled a third-party action for $725,000. The employer and carrier consented, expecting satisfaction of their lien and a future credit. Claimant sought reimbursement for legal expenses, but a Workers' Compensation Law Judge (WCLJ) declined an award without a closing statement. The Workers’ Compensation Board upheld this decision and assessed a $500 penalty against claimant’s counsel for pursuing proceedings without reasonable grounds. The appellate court affirmed the Board’s decision, finding substantial evidence supported the counsel fee assessment because the application for Board review was unnecessary given the requirement for a signed closing statement.