Matter of Docking v. Lapp Insulators LLC
Claimant, a hazmat driver, sustained an unwitnessed fall at work in July 2017, resulting in a traumatic brain injury and memory loss of the incident. He filed for workers' compensation benefits, which the employer controverted. A Workers' Compensation Law Judge (WCLJ) found that the Workers' Compensation Law § 21 presumption of compensability applied, and the employer failed to rebut it. The Workers' Compensation Board affirmed the WCLJ's decision. On appeal, the employer argued that the injury resulted from a preexisting cardiovascular condition, presenting an independent medical examination report. However, the Appellate Division, Third Department, affirmed the Board's determination, finding that the employer failed to provide substantial evidence to rebut the presumption that the accident was work-related, giving appropriate deference to the Board's credibility determinations.