Matter of Christie v. Universal Music Group
Claimant Jeffrey Christie, a tour manager for Universal Music Group, suffered injuries from an assault and filed a workers' compensation claim. The employer contested the claim, arguing Christie was an independent contractor. A Workers' Compensation Law Judge (WCLJ) found Christie to be an employee. The employer appealed to the Workers' Compensation Board, which denied their application for review, citing non-compliance with 12 NYCRR 300.13 (b) for failing to specify an objection. The Appellate Division, Third Department, affirmed the Board's decision, upholding its discretion to deny review for procedural deficiencies, noting that Workers' Compensation Law § 23-a, enacted later, would not apply retroactively to this case.