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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. 92-CV-1085
Regular Panel Decision

Capriotti v. Consolidated Rail Corp.

Plaintiff Salvatore Capriotti, a yardmaster for Conrail, suffered heart problems exacerbated by stressful work conditions and increased responsibilities after staff cutbacks. He sued Conrail under the Federal Employers’ Liability Act (FELA) for negligent infliction of emotional distress and a direct physical injury claim. Conrail renewed its motion for summary judgment based on the Supreme Court's reversal in Consolidated Rail Corp. v. Gottshall and Carlisle, which established the "zone of danger" test for emotional distress claims under FELA. The court found Capriotti's claim to be essentially the same as Carlisle's — "too much work, not too dangerous work" — and therefore, he did not meet the "zone of danger" requirement. The court also rejected his claim under the Hours of Service Act, stating that FELA parameters still apply, requiring proof of being in the zone of danger. Consequently, Conrail's motion for summary judgment was granted, and Capriotti's complaint was dismissed.

FELASummary JudgmentEmotional DistressZone of DangerStressful Work ConditionsHeart ConditionHours of Service ActNegligence Per SeRailroad Employment
References
11
Case No. MISSING
Regular Panel Decision

Louchheim v. Zoning Board of Appeals

Petitioners appealed a judgment from the Supreme Court, Suffolk County, which had denied their CPLR article 78 petition. The petition aimed to review a determination by the Zoning Board of Appeals of the Town of Southampton, dated October 20, 2005. The ZBA's determination had granted NL Housing, LLC, a variance for the enlargement of two structures that served as a labor camp for migrant workers, benefiting from a preexisting nonconforming use. The petitioners argued that this variance violated Southampton Code § 330-167 (B) (1) (a), also known as the 50% rule, which limits nonconforming use expansion to 50% of the floor area as measured from when the use first became nonconforming in 1957. The Appellate Court reversed the Supreme Court's judgment, granted the petition, annulled the ZBA's determination, and denied the application for the variance, finding that the ZBA had incorrectly interpreted the zoning ordinance.

ZoningVarianceNonconforming UseMigrant HousingZoning Board of AppealsCPLR Article 78Appellate ReviewStatutory Interpretation50% RuleSuffolk County
References
7
Case No. 2020-02-0173
Regular Panel Decision
Mar 18, 2021

Ramey, Joshua v. Sleep Zone, Inc.

Mr. Ramey requested additional workers' compensation benefits from Sleep Zone, Inc., for injuries sustained from a fall while carrying a mattress. Sleep Zone denied the claim based on surveillance video and the authorized treating physician, Dr. Jody Helms, who determined Mr. Ramey’s complaints were not causally related to the fall. Mr. Ramey’s credibility was questioned, especially his argument that the surveillance video depicted his twin brother. The Court found no medical proof supporting his claim and denied his requests for medical and temporary disability benefits, concluding he was unlikely to prevail on the merits.

CredibilitySurveillance VideoMedical CausationTemporary Disability BenefitsExpedited HearingAuthorized Treating PhysicianMaximum Medical ImprovementInjury ClaimMedical Treatment ComplianceFraud Allegations
References
2
Case No. MISSING
Regular Panel Decision

Residents Against Flooding v. Reinvestment Zone Number Seventeen

The case involves Residents Against Flooding (RAF) and individual plaintiffs suing the City of Houston, Reinvestment Zone Number Seventeen (TIRZ 17), and the Memorial City Redevelopment Authority. Plaintiffs sought declaratory and injunctive relief, alleging that defendants' drainage and development policies in TIRZ 17 caused increased flooding in their residential neighborhoods, violating their Fourth and Fourteenth Amendment rights and Article 1, Section 19 of the Texas Constitution. Specifically, they claimed defendants diverted stormwater, approved developments without sufficient mitigation, and postponed residential flood relief. The defendants filed motions to dismiss for lack of standing, failure to state a claim, and immunity. The Court dismissed the state-created-danger claims, found federal and state takings claims not ripe, and concluded that all Section 1983 claims were time-barred. Additionally, the Court found the Zone not a suable entity and dismissed claims based on governmental immunity, ultimately granting all motions to dismiss.

Municipal LiabilityFlood ControlProperty RightsConstitutional LawDeclaratory ReliefInjunctive ReliefDue ProcessFourth AmendmentFourteenth AmendmentEleventh Amendment
References
232
Case No. MISSING
Regular Panel Decision

Frangella Mushroom Farms, Inc. v. Zoning Board of Appeals

The petitioner, who operates a mushroom growing farm in the Town of Coeymans, sought a special use permit to construct an apartment building for its migrant laborers. The Zoning Board of Appeals denied the application, citing concerns related to aesthetic harmony, property values, safety, and traffic. However, the court found the Board's 17 specific findings to be arbitrary and capricious, lacking sufficient evidence in the record. The court determined that the proposed housing would not adversely affect the district and would replace existing substandard dwellings without increasing population or traffic. Consequently, the court annulled the Board's determination and mandated the issuance of the special use permit.

Zoning OrdinanceSpecial Use PermitArbitrary and CapriciousLand Use PlanningMigrant HousingAgricultural OperationsJudicial ReviewCPLR Article 78Town of CoeymansAlbany County
References
6
Case No. MISSING
Regular Panel Decision
Sep 23, 2005

Stamm v. PHH Vehicle Management Services, LLC

This case involves an appeal concerning plaintiffs Thoburn, III (Toby) and Cannon, who, as young children, were present during a car accident in 1985 that left their mother with severe and permanent brain injuries. They subsequently filed a lawsuit against their father, Thoburn M. Stamm, Jr., and PHH Vehicle Management Services, LLC, alleging physical and emotional injuries, specifically emotional distress and post-traumatic stress syndrome, under the 'zone of danger' theory. Defendants moved for summary judgment, arguing that the alleged emotional injuries were not proximately caused by the direct observation of their mother's serious injury during the accident. The Supreme Court initially denied the defendants' motions, but the appellate court unanimously reversed this decision, granting summary judgment to the defendants and dismissing the complaint with prejudice, concluding that plaintiffs failed to provide sufficient evidence to support their zone of danger claims.

Zone of DangerNegligent Infliction of Emotional DistressSummary JudgmentAppellate ReversalCar AccidentEmotional InjuryParental ConsortiumPsychiatric EvaluationEvidentiary StandardsProximate Causation
References
5
Case No. MISSING
Regular Panel Decision

Murphy v. Metropolitan Transportation Authority

Plaintiff James Murphy sued the Metropolitan Transportation Authority (MTA) under FELA, alleging a knee injury from unsafe workplace conditions and emotional distress from a supervisor's gun threats, as well as the MTA's order to return to a feared work environment. The court granted summary judgment for the MTA on the knee injury and the 'return to Penn Station' claims, determining no negligence was demonstrated for the stanchion placement, and the 'zone of danger' test was not met for the return order. However, summary judgment was denied for the negligent supervision claim concerning the gun threats, as a jury issue was found regarding the supervisor's violent propensities and the MTA's knowledge of them. Plaintiff's cross-motion to amend his complaint was also denied.

FELASummary JudgmentNegligenceEmotional DistressWorkplace SafetyIntentional TortRespondeat SuperiorNegligent SupervisionZone of DangerFederal Rules of Civil Procedure
References
36
Case No. MISSING
Regular Panel Decision
Jun 27, 1996

Martinez v. Southern Pacific Transportation Co.

Plaintiff Manuel C. Martinez sued Southern Pacific Transportation Company under the Federal Employers’ Liability Act (FELA), alleging that work-related stress, stemming from increased workload, reduced personnel, and lack of updated equipment (personal computer), led to his heart attack. The trial court granted summary judgment for Southern Pacific, ruling that there is no duty under FELA to provide a stress-free work environment, and such a claim does not fall within the "zone of danger" test established by the Supreme Court for negligent infliction of emotional distress. The appellate court affirmed the trial court's judgment, modifying it only to delete the dismissal "with prejudice" and instead state that the plaintiff "take nothing," as is proper for a summary judgment.

FELAFederal Employers' Liability ActNegligent Infliction of Emotional DistressWork-Related StressHeart AttackSummary JudgmentAppellate ReviewZone of Danger TestEmployer LiabilityRailway Employee
References
13
Case No. MISSING
Regular Panel Decision

Higgins v. Metro-North Railroad

Plaintiff Gail Higgins sued Metro-North Railroad Company under FELA, alleging sexual harassment by a co-worker, Militano, which she claimed caused her latent multiple sclerosis to become symptomatic. She asserted claims of negligent failure to provide a safe workplace, negligent supervision, intentional infliction of emotional distress, and negligent infliction of emotional distress. The court granted defendant's motion for summary judgment, ruling that Higgins did not suffer a "physical impact" as required for negligent infliction of emotional distress under FELA's "zone of danger" test, as she was not physically injured nor in apprehension of physical harm. Furthermore, her claim for intentional infliction of emotional distress failed because Metro-North could not be held vicariously liable for Militano's actions, as his misconduct was for personal motives. There was also insufficient evidence that Metro-North knew of Militano's propensity for sexual harassment to support a negligent supervision claim.

Federal Employers' Liability ActSexual Harassment ClaimsNegligent Infliction of Emotional DistressIntentional Infliction of Emotional DistressSummary Judgment MotionZone of Danger TestPhysical Impact RequirementLatent Multiple SclerosisEmployer Vicarious LiabilityNegligent Supervision
References
34
Case No. MISSING
Regular Panel Decision

In Re Morton

Michael Wayne Morton, convicted of his wife's murder in 1987, sought post-conviction forensic DNA testing of various pieces of evidence under chapter 64 of the Texas Code of Criminal Procedure. The district court partially denied his motion, leading to this appeal. The appellate court affirmed the denial of testing for evidence related to a separate murder and for fingerprint evidence, finding these did not meet the statutory requirements of being "secured in relation to the offense" or containing "biological material." However, the court reversed the denial for a blood-stained bandana recovered near the crime scene. The court concluded that if DNA testing on the bandana yielded exculpatory results (Christine's blood and a third party's DNA), there is a greater than 50% likelihood that Morton would not have been convicted, and thus remanded the case for further proceedings concerning the bandana.

forensic DNA testingmurder convictionappealcriminal procedureexculpatory evidenceblood-stained bandanaunidentified fingerprintscircumstantial evidencetime of deathunknown intruder theory
References
12
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