Rosenblum v. New York State Workers' Compensation Board
Petitioner, Jay Alan Rosenblum, M.D., brought a CPLR article 78 proceeding challenging the Workers’ Compensation Board’s (WCB) interpretation of Workers’ Compensation Law § 137 (3) (a). Dr. Rosenblum, a neurologist certified by the WCB since 1966, was denied authorization to conduct independent medical examinations under new regulations. These regulations mandated that such examinations be conducted by physicians 'board certified' by specialty boards recognized by the American Board of Medical Specialties (ABMS) or the American Osteopathic Association (AOA). Dr. Rosenblum, an M.D. without ABMS/AOA certification, argued that the WCB’s narrow definition was improper and that the regulations should have included a grandfathering provision. The court upheld the WCB’s interpretation, finding it neither arbitrary nor capricious, emphasizing judicial deference to agency expertise. Consequently, the court denied the petition to vacate the denial and annul the regulations, and granted the WCB’s motion to dismiss the proceeding.