Matter of Shmulsky v. Hudson Headwaters Health Network, Inc.
Claimant Katherine Shmulsky sought workers' compensation benefits for dysautonomia, alleging it was a causally-related injury from a COVID-19 vaccination received in December 2020 while employed by Hudson Headwaters Health Network, Inc. Although a Workers' Compensation Law Judge initially established the claim, the Board reversed, finding that claimant failed to demonstrate her injuries arose out of and in the course of her employment, as the vaccination was encouraged but not mandated by the employer, with no repercussions for refusal. Claimant's application for reconsideration was denied. The Appellate Division, Third Department, affirmed both Board decisions, concluding that the Board's determination was supported by substantial evidence.