Belmonte v. Snashall
The case involves licensed physicians challenging the Workers' Compensation Board's interpretation of "board certified" concerning independent medical examinations (IMEs) under Workers' Compensation Law § 137 (3) (a). The Board had defined "board certified" as certification by a specialty board recognized by the American Board of Medical Specialties (ABMS) or the American Osteopathic Association (AOA), which the petitioners disputed. The Supreme Court initially sided with the petitioners, invalidating the Board's interpretation and regulations, and annulling denials of authorization. On appeal, the court held that the Board's interpretation was not owed deference as it was a matter of pure statutory interpretation. The appellate court concluded that the Legislature intended "board certified" to mean certification by the Workers' Compensation Board itself, rather than by external medical specialty boards, and therefore affirmed the lower court's judgment.