Citron v. Staten Island University Hospital
The claimant, a respiratory therapist at Staten Island University Hospital, sustained an off-duty back injury in November 1991 and subsequently received disability benefits. In November 1992, the claimant was discharged for failing to provide documentation regarding her ongoing inability to return to work, despite repeated requests from her employer. She filed a complaint, alleging that her termination was in retaliation for filing a disability claim, in violation of Workers’ Compensation Law § 120. The Workers’ Compensation Board dismissed her complaint. The appellate court affirmed the Board's decision, concluding that there was substantial evidence to support the finding that her discharge was solely due to her failure to cooperate with the employer's documentation requests, not retaliatory intent.