Walczyk v. Lewis Tree Service, Inc.
Claimant, a tree service worker, sustained a back injury in 2005 and later bilateral carpel tunnel syndrome in 2007, which was established as an occupational disease. The Workers’ Compensation Law Judge initially determined a 15% schedule loss of use for each hand due to carpel tunnel syndrome, leading to an award of $29,280. However, due to concurrent compensation for the back injury and the statutory weekly cap of $400, the Judge reduced the carpel tunnel award to $2,916, payable weekly. The Workers’ Compensation Board modified this, ruling that the claimant was entitled to the full $29,280 schedule loss of use award for the carpel tunnel syndrome, payable in a lump sum, citing Workers’ Compensation Law §§ 15 (3) (u) and 25 (1) (b) as amended in 2009. The employer's carrier appealed, arguing this violated the maximum disability rate provisions. The appellate court affirmed the Board's decision, stating that the lump-sum payment was an authorized alternative and did not violate the statutory cap, and that prior precedent did not preclude such an award.