Thousand v. Human Resources Administration
The case involves an appeal from an amended decision by the Workers’ Compensation Board regarding a death benefits claim. The claimant’s decedent, Marion Holmes-Thousand, suffered a fatal heart attack at work in 1984, and a claim was filed two years later, exceeding the 30-day notice requirement. Both the Workers’ Compensation Law Judge and the Board excused the late notice, finding the employer, Neighborhood Action Board #2, and its insurer, Zurich Insurance Company, were not prejudiced. Zurich appealed this decision, arguing it was prejudiced by the delay and inability to investigate or file a claim under Workers’ Compensation Law § 15 (8) (e). The court affirmed the Board’s decision, concluding that substantial evidence supported excusing the late notice due to the employer’s actual knowledge of the death and Zurich’s failure to demonstrate actual prejudice despite opportunities for investigation.