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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

Claim of Price v. KGM Plastic Industries

Claimant, a sales president for Caprice and KGM Plastic Industries, experienced severe emotional distress due to ongoing conflicts with his superior, Toshimasa Asai, regarding business decisions and job security. This culminated in a heated argument on January 6, 1983, after which the claimant became ill, developed nosebleeds, and suffered a stroke on January 11, 1983, leading to permanent disability. His physician testified that the stroke was causally related to job-induced emotional stress exacerbating pre-existing hypertension. The Workers' Compensation Board found a causally related disability, and this decision was affirmed on appeal, supported by substantial medical evidence despite controverting opinions.

Work-related disabilityEmotional distressCerebral vascular accidentStrokeHypertension exacerbationCausationWorkers' Compensation LawAppellate reviewSubstantial evidenceEmployer-employee conflict
References
3
Case No. MISSING
Regular Panel Decision

Claim of Ancrum v. New York City Board of Education

Claimant appealed a Workers' Compensation Board decision from September 22, 2008, which affirmed a Workers' Compensation Law Judge's finding that the claimant had no further causally related disability after March 14, 2007. The initial claim stemmed from a compensable injury sustained in February 2005, which the employer subsequently controverted based on an independent medical examination. The Appellate Division affirmed the Board's decision, stating that it was supported by substantial evidence and that the Board had the discretion to resolve conflicting medical opinions. Despite a chiropractor's testimony of a permanent partial disability, the court noted that the treating physician and the employer's medical expert opined against a work-related disability, which the Board was entitled to credit.

Disability BenefitsCausationMedical EvidenceConflicting Medical OpinionsAppellate ProcedureJudicial ReviewSubstantial Evidence StandardBoard DiscretionChiropractic ExpertEmployer's Medical Expert
References
5
Case No. MISSING
Regular Panel Decision
Jan 09, 1991

Claim of Ingham v. Oswego County

The claimant, a nursing assistant for Oswego County, sustained multiple injuries, including to the knee, back, wrist, and head, in an August 1979 accident while assisting a client. Over time, the claimant's condition deteriorated, leading to permanent total disability. A Workers’ Compensation Law Judge initially found a causally related disability for the knee and wrist, later amending it to include the low back and consequential obesity. The self-insured employer, Oswego County, appealed this decision, arguing the back injury claim was untimely and that the disability should be apportioned due to the claimant's prior back history and obesity. The Workers’ Compensation Board affirmed the WCLJ's decision, rejecting the County’s arguments by finding a waiver of the timeliness objection and substantial evidence supporting the aggravation of preexisting conditions as causally related to the 1979 accident, leading to total disability.

Permanent Total DisabilityCausally Related DisabilityAggravation of Preexisting ConditionWaiver of Section 28 DefenseTimeliness of Claim ObjectionConflicting Medical EvidenceSpinal InjuryObesity-Related DisabilityJoint InjuryEmployer Self-Insured
References
3
Case No. MISSING
Regular Panel Decision

Claim of Hercules v. United Artists Communications, Inc.

The claimant appealed a decision by the Workers’ Compensation Board, filed June 20, 1988, which ruled that the claimant did not sustain a causally related disability. The Board had found the claimant's initial claim for a right knee injury, sustained in September 1982, barred by Workers’ Compensation Law § 28 due to late filing in November 1984. Regarding a second claim for injuries sustained on October 11, 1983, the Board determined only the right shoulder injury was causally related to the work accident, denying a causally related disability for other injuries. The appellate court affirmed the Board’s decision, rejecting the claimant's arguments that the Board's findings lacked substantial evidence, failed to consider all relevant evidence, or erred in denying requests for reopening and reconsideration. The court concluded that the Board's factual findings were supported by substantial evidence and its discretionary denials were not arbitrary or capricious.

Workers' CompensationAppealDisabilityCausal RelationshipStatute of LimitationsEvidenceCredibilityJudicial DiscretionKnee InjuryShoulder Injury
References
3
Case No. MISSING
Regular Panel Decision

Claim of Pinto v. Southport Correctional Facility

Claimant, a teacher at a maximum-security correctional facility, experienced severe head pains and disorientation, leading to a claim for workers' compensation benefits for work-related stress, depression, headaches, and memory loss. The Workers’ Compensation Board disallowed the claim, finding the presumption of work-related injury rebutted and concluding that the stress experienced was not greater than that usually encountered in his work environment. On appeal, the court affirmed the Board’s decision to deny the claim on the merits. While the court disagreed with the Board's finding that the claim was barred by Workers’ Compensation Law § 2 (7) due to personnel decisions, it upheld the Board's alternate basis for denial, stating that the claimant failed to show the stress was beyond what similarly situated workers experienced.

Workers' CompensationStress-related injuryMental injuryCausationPresumption of injuryRebuttal of presumptionPersonnel decisionWork environmentCorrectional facilityTeacher
References
14
Case No. MISSING
Regular Panel Decision

Claim of Scheriff v. Wichmann Co.

The claimant appealed a Workers' Compensation Board decision that denied a finding of further causally related disability and closed the case without prejudice. The Board had reversed a Workers' Compensation Law Judge's decision and found the claimant failed to provide updated evidence of a continuing causally related disability after September 2002. On appeal, the claimant argued there was ample medical evidence to support a permanent partial disability finding. However, the Court found the opinions from three physicians (Mohler, Wirth, and Bilfield) to be conflicting and inconclusive regarding permanency. Therefore, the Court affirmed the Board's decision, concluding it was within the Board's discretion to require further evidence before determining permanency and dismissing due process arguments regarding future record development.

Workers' Compensation BenefitsCausally Related DisabilityPermanent Partial DisabilityMaximum Medical ImprovementVoluntary Withdrawal from Labor MarketApportionmentMedical EvidenceBoard DiscretionDue ProcessAppellate Division
References
5
Case No. MISSING
Regular Panel Decision

Price v. Hudson Correctional Facility

Claimant, a correction counselor, ceased working in August 1992 at age 52 due to various health issues, including established work-related stress, anxiety, and panic disorder, eventually retiring in July 1995. A WCLJ initially found permanent total disability and a moderate causally related permanent partial disability, deeming the voluntary withdrawal issue moot. The Workers’ Compensation Board modified this, finding a moderate partial causally related disability until 1995 but ruling claimant voluntarily withdrew from the labor market upon retirement, denying further benefits. The appellate court reversed, clarifying that a work-related disability only needs to contribute to, not be the sole cause of, retirement to avoid voluntary withdrawal, and found the medical evidence established total disability at the time of retirement, partially due to work-related conditions.

Workers' CompensationVoluntary WithdrawalLabor MarketPermanent Total DisabilityPermanent Partial DisabilityCausally Related DisabilityStressAnxietyPanic DisorderMedical Evidence
References
3
Case No. MISSING
Regular Panel Decision

Underwood v. Zurich Insurance Co.

Cas Underwood, an employee of BASF Corporation, sustained work-connected injuries from an explosion. He received a lump-sum disability award, which was later paid by Zurich Insurance Company. Subsequently, Underwood was diagnosed with Post-traumatic Stress Disorder (PTSD) and petitioned to reopen the final judgment, seeking additional disability benefits. The trial court dismissed his petition to reopen, citing a Tennessee statute on the finality of lump-sum payments, but granted his motion for future medical expenses related to PTSD. On appeal, the Supreme Court of Tennessee affirmed the trial court's decision, concluding that an increase in disability after a lump-sum award does not constitute grounds for relief under Tenn.R.Civ.P. 60.02(5) and that timely notice was given for medical expenses.

Workers' CompensationPost-traumatic Stress DisorderLump-sum SettlementFinality of JudgmentRule 60.02Increased DisabilityMedical ExpensesNotice RequirementAppellate ReviewStatutory Interpretation
References
17
Case No. MISSING
Regular Panel Decision
Oct 21, 1994

Claim of Troy v. Prudential Insurance

The claimant, an insurance agent, resigned from his position in October 1990 due to depression and anxiety allegedly caused by job-related stress. The Workers’ Compensation Board denied his claim for benefits, ruling that his disabling mental condition was not employment-related, as the stress was not greater than that normally occurring in the work environment. Conflicting testimony was presented regarding the cause of his emotional problems, with some suggesting personal circumstances and normal work stress, while others pointed to unusually intense workplace pressure. The Board determined that the disability was not sustained in the course of employment, a finding which the appellate court affirmed based on substantial evidence in the record. Consequently, the claimant was deemed ineligible for workers' compensation benefits.

Workers' CompensationJob StressMental Health DisabilityCausationAppellate ReviewBoard DecisionEmployment-Related StressMedical EvidenceSubstantial EvidenceNormal Work Environment
References
3
Case No. MISSING
Regular Panel Decision

Claim of Wiltsie v. Owens Corning Fiberglass

Claimant suffered a compensable low back injury in 1995, continuing work with restrictions and ADA accommodations. In 2003, the employer's decision to change his shift caused claimant stress, leading his primary physician to diagnose chest pain syndrome, agoraphobia, and depression, and advise him to stop working. Initially awarded benefits for a period, the Workers’ Compensation Board subsequently denied further benefits, concluding that claimant's departure from work was for reasons unrelated to his back disability. Claimant appealed, contending his back injury prevented him from the new shift, but the Board's determination, supported by other evidence, found he left due to stress from the shift dispute rather than his back condition. The Board's decision, which included an assessment of claimant's testimony and medical evidence, was affirmed, as it was supported by credible evidence.

Low Back InjuryAmericans with Disabilities Act (ADA)Workplace AccommodationShift Schedule ChangeStress-Related IllnessChest Pain SyndromeAgoraphobiaDepression DiagnosisCredibility of Medical OpinionPermanent Partial Disability
References
5
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