Matter of Brown v. New York City Tr. Auth.
Claimant Tracey Brown, a cleaner, sought workers' compensation benefits for anxiety and depression, attributing them to COVID-19 exposure and inadequate safety measures at the New York City Transit Authority. Despite a prior anxiety history, claimant contended her condition re-emerged after a May 2020 anxiety attack, preventing her return to work. Psychologist Eli Isaacson diagnosed a causally-related anxiety and major depressive disorder. However, a Workers' Compensation Law Judge (WCLJ) and subsequently the Workers' Compensation Board disallowed the claim, citing a lack of credible medical evidence linking the psychological condition to employment. The Appellate Division affirmed this decision, concurring that Isaacson's opinion lacked credibility due to its failure to consider claimant's prior anxiety treatment and anxiety experienced outside of work.