Claim of Estate of Seitz v. Jacobson & Co.
This appeal concerns the timeliness of a supplemental application for review in a workers' compensation death benefits claim. John Seitz, a sheet metal worker, died from asbestosis-related lung cancer. His surviving spouse filed for benefits but died before causality was established, leading a WCLJ to close the case. The decedent's estate sought to reopen the case, and although a WCLJ initially ruled the claim abated upon the spouse's death, the estate filed for Board review. After being granted an extension by the Board's Office of Appeals, the estate filed a supplemental application arguing for benefits under Workers' Compensation Law § 16 (4-b). However, a Board panel subsequently deemed this application untimely and denied the claim. The Appellate Court reversed, finding the Board abused its discretion by rejecting the application as untimely after granting an extension, and also noted the Board's unexplained departure from prior precedents. The case was remitted to the Workers’ Compensation Board for further proceedings.