Claim of Liberius v. New York City Health & Hospitals Corp.
The claimant suffered work-related injuries and was awarded compensation for a permanent partial disability through conciliation. The self-insured employer delayed payment, leading the claimant to seek a 20% penalty under Workers’ Compensation Law § 25 (3) (f). However, a WCLJ and the Workers’ Compensation Board imposed only a $500 fine under Workers’ Compensation Law § 25 (2-b) (h), citing a regulation that exempted conciliation cases from the 20% penalty. On appeal, the Court reversed, ruling that the statutory 20% penalty applies to conciliation awards and that the regulation (12 NYCRR 312.5 [j]) which barred it was invalid for conflicting with the enabling statute.