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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

In re the Claim of Uhler v. A & P

Claimant suffered electrocution injuries in 1981, initially affecting his left hand and later manifesting as brain trauma. In 1989, the Workers' Compensation Board reopened the case, finding that the Statute of Limitations was tolled due to the claimant's mental incompetency, which stemmed from the electrocution. The Board awarded workers' compensation benefits for the brain trauma and absolved the Special Fund for Reopened Cases from liability. The employer appealed, but the court affirmed the Board's findings, citing substantial evidence of mental incompetence, the tolling of the Statute of Limitations, and the claimant's total disability. The court also agreed that Workers’ Compensation Law § 25-a was inapplicable.

Mental IncompetencyStatute of LimitationsBrain TraumaElectrocution InjuryTotal DisabilityMedical Expert TestimonyWorkers' Compensation BenefitsSpecial Fund LiabilityPersonality DisorderMemory Loss
References
3
Case No. ADJ1167245
Regular
Jun 03, 2013

RONALD THOMPSON vs. BLOCKA CONSTRUCTION, INC., SEABRIGHT INSURANCE COMPANY

The Workers' Compensation Appeals Board granted reconsideration to amend an award concerning an electrocution injury. The Board modified the award to have the EDD lien for duplicative payments deducted from the applicant's permanent disability award, rather than reimbursed separately by the defendant, and rescinded the award of interest to EDD. The Board affirmed the WCJ's findings of 100% permanent disability without apportionment and the exclusion of sub rosa video evidence. The matter was returned to the WCJ to recalculate the commutation of the award to incorporate the EDD lien payment.

Electrocution injuryPermanent disabilityApportionmentSub rosa videoEDD lienCommutationDuplicative paymentsVocational rehabilitationMedical evidenceCardiac disability
References
0
Case No. ADJ12315169
Regular
Sep 10, 2019

Gregory Williams vs. Redwood Electric Group, Travelers Property Casualty Company of America

The Appeals Board affirmed an Arbitrator's finding that an electrician's injuries, potentially from electrocution, arose out of employment. Despite the unwitnessed nature of the injury and lack of direct evidence on the precise cause, the Board applied the *Clemmens* doctrine, creating a presumption that the injury occurred in the course of employment when the employee is placed at the location by the employer. Circumstantial evidence, including entry and exit wounds and the active construction site environment, supported the industrial nature of the injury. The defendant's arguments regarding the neutral risk doctrine, burden of proof, and denial of due process were found unpersuasive or waived.

Workers' Compensation Appeals BoardRedwood Electric GroupTravelers Property Casualty Company of AmericaJourneyman Electricianupper and lower extremitiesbody systemskinkidneysheartbrain
References
2
Case No. MISSING
Regular Panel Decision

Di Piazza v. George Campbell Painting Co.

The case involves the appeal of a Workers' Compensation Board decision concerning a decedent's widow. The decedent sustained fatal injuries from electrocution while working for the employer. The Board initially awarded death benefits, temporary total disability, and facial disfigurement, but later rescinded the disability award, upholding the disfigurement. The employer appealed, arguing the disfigurement award was improper without a permanent partial disability finding. The court reversed the Board's decision, finding that the evidence of grave injuries supported total, not partial, disability, making the disfigurement award irrational. The matter was remitted for further proceedings consistent with the court's decision.

Workers' CompensationFacial DisfigurementTemporary Total DisabilityDeath BenefitsConcurrent AwardsAppellate ReviewStatutory InterpretationMedical EvidenceAccidentElectrocution
References
4
Case No. MISSING
Regular Panel Decision

Casale v. Unipunch, Inc.

This case concerns a plaintiff seeking recovery for emotional distress and pecuniary damages after witnessing the electrocution of a co-worker at a defendant's work site. The plaintiff appealed the dismissal of the emotional distress claim, while the defendant cross-appealed the denial of dismissing the pecuniary damages claim. The court reviewed New York's bystander recovery rules, emphasizing that recovery for emotional injury from witnessing harm to a third person is generally precluded. The court found that the plaintiff did not meet the 'zone of danger' exception from Bovsun v Sanperi because the injured party was not an immediate family member. Consequently, both the emotional distress and the associated pecuniary damages claims were dismissed, modifying the lower court's order.

Emotional DistressPecuniary DamagesBystander RecoveryZone of DangerNegligenceCo-worker InjurySummary JudgmentAppellate LawDuty of CareNew York Law
References
8
Case No. MISSING
Regular Panel Decision
Mar 29, 1985

Jaroszewicz v. Facilities Development Corp.

Plaintiff's husband, a maintenance mechanic, was electrocuted while trouble-shooting an electrical problem at the Westchester County Medical Center. Plaintiff sued the project architects, C. F. Murphy Associates and Lothrop Associates, alleging liability under Labor Law § 241 for breach of the duty to provide a safe place to work, and under a common-law negligence theory for improper supervision. The Supreme Court granted summary judgment to the architects. On appeal, the court affirmed, holding that Labor Law § 241 did not apply as the accident occurred after construction completion. Furthermore, the architects were not liable for common-law negligence as their contractual duty was to the Facilities Development Corporation, they lacked control over construction methods, and no active malfeasance was proven.

construction accidentelectrocutionarchitect liabilitysummary judgmentLabor Lawduty to provide safe place to workimproper supervisionpost-construction accidentagency liability
References
5
Case No. MISSING
Regular Panel Decision

Haughton v. T & J Electrical Corp.

Plaintiff Archebald C. Haughton, Jr., a maintenance worker at Hudson Valley Community College, suffered severe injuries from electrocution while attempting to restore power during an outage. Despite knowing that the power company, Niagara Mohawk, was assembling a crew, plaintiff's supervisors directed him to work on high-voltage equipment in a dark and smoky room, without proper protective gear. Plaintiff and his wife sued Niagara Mohawk and T & J Electrical Corporation, an electrical contractor, alleging breach of duty of care. The Supreme Court granted summary judgment to the defendants, concluding that the actions of the plaintiff and his supervisors constituted an unforeseeable intervening act. The Appellate Division affirmed this decision, absolving the defendants of liability.

Summary JudgmentProximate CauseIntervening ActElectrocutionWorkplace AccidentHigh VoltageDuty of CareNegligenceAppellate ReviewEmployer Liability
References
8
Case No. MISSING
Regular Panel Decision

Fuchs v. Austin Mall Associates, LLC

The plaintiff appealed a Supreme Court order granting summary judgment to defendants, dismissing causes of action under Labor Law §§ 241(6), 200, and common-law negligence. The decedent was electrocuted while replacing an elevator ceiling on property owned and/or managed by the defendants. The Appellate Division found that the decedent's work constituted "alteration" under Labor Law § 241(6) and that the plaintiff's failure to assert a specific Industrial Code provision was not fatal. The court also determined that a triable issue of fact existed regarding the defendants' notice of the dangerous condition for the Labor Law § 200 and common-law negligence claims. Consequently, the Supreme Court's order was reversed, and the defendants' motion for summary judgment was denied.

Wrongful DeathConscious Pain and SufferingSummary JudgmentAppealLabor Law § 241(6)Labor Law § 200Common-Law NegligencePremises LiabilityElectrocution AccidentElevator Repair
References
12
Case No. MISSING
Regular Panel Decision

Baumann v. Metropolitan Life Insurance

Plaintiff's decedent, Frederick Baumann, an experienced electrician, was electrocuted on the job in 1999 while working on office space leased by Credit Suisse and owned by Met Life. Plaintiff commenced a wrongful death action against Met Life, Credit Suisse, and Penguin Air Conditioning Corp., alleging liability under Labor Law § 241 (6) for a violation of 12 NYCRR 23-1.13 (b) (4). The trial court granted summary judgment to Credit Suisse and Met Life, concluding that the decedent was the sole proximate cause of his death. The appellate court reversed this decision, finding that the trial court improperly made findings of fact and that there were questions of fact concerning the defendants' liability and the extent of the decedent's responsibility.

Wrongful DeathElectrocutionSummary JudgmentLabor LawProximate CauseSuperseding ActAppellate ReviewConstruction AccidentElectricianOccupational Hazard
References
1
Case No. MISSING
Regular Panel Decision
Aug 24, 1990

Tuohey v. Gainsborough Studios, Inc.

Plaintiff's decedent, a construction worker, was electrocuted while working on a scaffold due to an ungrounded chipping hammer. The building owner, Gainsborough Studios, Inc., moved for summary judgment, arguing against liability under Labor Law §§ 240 (1) and 241 (6). The Supreme Court granted summary judgment, finding § 240 (1) inapplicable and noting a lack of owner control or notice for § 241 (6). However, the appellate court modified this decision, reversing the summary judgment on the Labor Law § 241 (6) claim. The appellate court emphasized that Labor Law § 241 (6) imposes a nondelegable duty on owners for worker safety, making them vicariously liable for contractor negligence even without direct supervision or notice of the defect.

construction accidentelectrocution hazardscaffolding lawpremises liabilitystatutory dutynondelegable dutyvicarious liabilitysummary judgment appealowner's liabilitysafety regulations
References
7
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