In the Matter of the Claim of IRA Jason Lucks, as Executor of the Estate of Julius Lucks, Deceased, Claimant
Julius Lucks suffered a work-related myocardial infarction in 1980, with liability initially against Continental Casualty Company (CNA) before being transferred to the Special Fund for Reopened Cases. After Julius's death in June 2013, his executor, Ira Jason Lucks, filed a claim for consequential death benefits. The Workers' Compensation Board ruled that CNA was the proper carrier for the death benefit claim, citing the failure to raise the applicability of Workers' Compensation Law § 25-a prior to the January 1, 2014 cutoff date. The Appellate Division affirmed the Board's decision, emphasizing that for relief from the Special Fund under Workers' Compensation Law § 25-a (1-a), both the accrual of the death benefit claim and the application for transfer of liability must occur before the January 1, 2014 deadline.