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

Case No. 2019 NY Slip Op 04065 [173 AD3d 105]
Regular Panel Decision
May 23, 2019

Hernandez v. State of New York

This case addresses the constitutionality of the farm laborer exclusion in New York's State Employment Relations Act. Plaintiffs, led by Crispin Hernandez, alongside the State of New York, challenged this exclusion as violating constitutional rights, including the right to organize and collectively bargain, and equal protection. Defendant New York Farm Bureau, Inc. intervened and successfully moved to dismiss the complaint at the Supreme Court level. On appeal, the Appellate Division reversed, ruling that the constitutional right to organize and collectively bargain is fundamental and the farm laborer exclusion fails to withstand strict scrutiny. Consequently, the court declared Labor Law § 701 (3) (a) unconstitutional, though a dissenting opinion argued for its constitutionality under rational basis review and against the immediate declaration.

Constitutional LawLabor LawFarm LaborersCollective Bargaining RightsEqual Protection ClauseDue ProcessFreedom of AssociationStrict ScrutinyRational Basis ReviewAppellate Procedure
References
61
Case No. MISSING
Regular Panel Decision

DeLeon v. Gurda Farms, Inc. (In Re Gurda Farms, Inc.)

This case involves an appeal by thirteen migrant seasonal farmworkers (plaintiffs-appellants), who are creditors of defendants-bankrupts Gurda Farms, Inc. and Stanley Gurda. The farmworkers challenged a Bankruptcy Court order that denied their request to proceed in forma pauperis (without payment of fees) in their appeal. The plaintiffs had previously obtained a judgment against the defendants under the Farm Labor Contractor Registration Act of 1963 and were prosecuting that action in forma pauperis when the defendants filed for bankruptcy, automatically staying the civil suit. The core legal question is whether 28 U.S.C. § 1915(a), which allows individuals to proceed in forma pauperis, is applicable to creditors appealing a bankruptcy court's decision, especially given the Supreme Court's ruling in United States v. Kras. The District Court distinguished this case from Kras, noting the plaintiffs' pre-existing in forma pauperis status and the minimal impact on the bankruptcy system's self-supporting goal. The court granted the plaintiffs leave to prosecute this appeal in forma pauperis.

In Forma PauperisBankruptcy AppealCreditor RightsFarm Labor Contractor Registration ActStatutory InterpretationConstitutional LawDue ProcessEqual ProtectionReferees' Salary ActBankruptcy Fees
References
13
Case No. 2024 NY Slip Op 01944 [226 AD3d 836]
Regular Panel Decision
Apr 10, 2024

Ragusa v. Drazie's Farm II, LLC

The plaintiff, Matthew Ragusa, appealed an order denying his cross-motion to amend the complaint to add Drazie's Farm, LLC as a defendant and granting summary judgment to Drazie's Farm II, LLC on a Labor Law § 240 (1) claim. The Appellate Division, Second Department, affirmed the lower court's decision. The court found that the relation-back doctrine did not apply because Drazie's Farm II, LLC and Drazie's Farm, LLC were separate entities with potentially different defenses, thus not united in interest. Furthermore, Drazie's Farm II, LLC established that it did not own the property where the accident occurred and therefore could not be held liable under Labor Law § 240 (1).

Personal injuryLabor Law § 240 (1)A-frame ladderfall from heightpremises liabilityrelation-back doctrinesummary judgmentlimited liability companyproperty ownershipadjoining properties
References
10
Case No. MISSING
Regular Panel Decision

Admiral Insurance v. State Farm Fire & Casualty Co.

The case involves an insurance dispute between Admiral Insurance Company and P&K (plaintiffs) and State Farm (defendant) concerning coverage for an underlying personal injury lawsuit. P&K, a contractor, was supposed to be covered as an additional insured under a State Farm policy through its subcontractor, Shahid Enterprises. After a Shahid employee was injured, triggering a lawsuit against P&K, Admiral sought defense and indemnification from State Farm, which disclaimed coverage due to late notice. The Supreme Court denied both parties' motions for summary judgment, finding that Insurance Law § 3420 (d) applied but a factual dispute existed regarding the timeliness of State Farm's disclaimer. The Appellate Division affirmed this decision, concluding that triable issues of fact remained as to whether Admiral's failure to provide information contributed to State Farm's delay in disclaiming coverage.

Insurance disputeDisclaimer of coverageLate noticeAdditional insuredSummary judgmentTriable issues of factInsurance Law § 3420 (d)Co-primary insurerIndemnificationDeclaratory judgment
References
17
Case No. MISSING
Regular Panel Decision

Lewis Family Farm, Inc. v. New York State Adirondack Park Agency

Lewis Family Farm (Lewis Farm) sought to build housing for farm workers in Essex County, within the Adirondack Park. The Adirondack Park Agency (APA) asserted jurisdiction, issued a cease and desist order, and levied a $50,000 civil penalty, claiming the structures were 'single family dwellings' requiring a permit. Lewis Farm challenged this, contending the housing constituted 'agricultural use structures' exempt from APA jurisdiction under the Adirondack Park Agency Act and the Wild, Scenic and Recreational Rivers System Act. The Supreme Court annulled the APA's determination, agreeing with Lewis Farm. The Appellate Division affirmed the Supreme Court's judgment, concluding that farmworker housing directly and customarily associated with agricultural use falls under the 'agricultural use structure' exemption, thus not requiring an APA permit.

Land UseAdirondack Park Agency ActAgricultural Use StructuresSingle Family DwellingsPermit RequirementsStatutory InterpretationCPLR Article 78Farmworker HousingZoning ExemptionEnvironmental Law
References
15
Case No. MISSING
Regular Panel Decision

Champagne v. State Farm Mutual Automobile Insurance

Selma Champagne appealed an order denying her motion for summary judgment and granting cross-motions by State Farm and John L. Homan. The case originated from a 1987 motor vehicle accident where Homan allegedly struck Samuel Champagne, who later settled with State Farm for the policy limit. Selma, Samuel's wife, then sought a declaratory judgment that State Farm was obligated to defend and indemnify Homan in her separate suit for loss of consortium. The Supreme Court initially granted summary judgment to both defendants. The appellate court modified the order, denying Homan's cross-motion, ruling that Selma's loss of consortium claim remained viable despite her husband's settlement as she was not a party to it. However, the court affirmed the summary judgment for State Farm, holding that State Farm had fulfilled its policy obligations by paying the "per person" bodily injury limit to Samuel, as loss of consortium damages are derivative and do not constitute a separate "bodily injury" under the insurance policy.

Loss of ConsortiumMotor Vehicle AccidentDeclaratory JudgmentSummary JudgmentInsurance Policy LimitsBodily InjuryDerivative ClaimSettlementAppellate ReviewPolicy Interpretation
References
10
Case No. MISSING
Regular Panel Decision

Duffy v. State Farm Mutual Automobile Insurance

Plaintiff Mary Duffy sued her former employer, State Farm Mutual Automobile Insurance Company, alleging age discrimination and retaliation after she was terminated at age 59. Duffy claimed harassment and a vendetta by supervisors, while State Farm maintained she was incompetent, accommodated her performance issues repeatedly, and fired her for poor work and bad attitude. The court reviewed her Age Discrimination in Employment Act (ADEA) claim and her retaliation claim, applying the McDonnell Douglas burden-shifting analysis. Though Duffy established a prima facie case, she failed to demonstrate that State Farm's legitimate, non-discriminatory reasons for termination were a pretext for discrimination or retaliation. Consequently, the court granted summary judgment in favor of State Farm on both claims.

Age DiscriminationRetaliation ClaimSummary JudgmentADEA (Age Discrimination in Employment Act)McDonnell Douglas AnalysisPrima Facie CasePretext for DiscriminationJob PerformanceEmployee TerminationWorkplace Harassment
References
17
Case No. 2014-1947 K C
Regular Panel Decision
Sep 08, 2017

Acupuncture Now, P.C. v. State Farm Mut. Auto. Ins. Co.

This case involves an appeal by Acupuncture Now, P.C., as assignee, against State Farm Mutual Automobile Insurance Co. from an order of the Civil Court. The order granted State Farm's motion for summary judgment to dismiss certain causes of action and to compel plaintiff's deposition. Acupuncture Now, P.C. contested State Farm's fee reductions for acupuncture services, which were based on the workers' compensation fee schedule for chiropractors. The Appellate Term affirmed the lower court's decision, upholding that insurers may use this fee schedule for licensed acupuncturists. Furthermore, the court found the order compelling plaintiff's deposition proper, as State Farm was defending the remaining cause of action on grounds of lack of medical necessity.

No-fault benefitsAcupuncture servicesFee scheduleWorkers' compensationSummary judgmentDepositionMedical necessityInsurance disputeAppellate TermChiropractic services
References
2
Case No. 2013-2706 Q C
Regular Panel Decision
Sep 19, 2016

NYS Acupuncture, P.C. v. State Farm Mut. Auto. Ins. Co.

This case, NYS Acupuncture, P.C. v State Farm Mut. Auto. Ins. Co., concerned an appeal from an order of the Civil Court of the City of New York, Queens County. The plaintiff, NYS Acupuncture, P.C., sought assigned first-party no-fault benefits from State Farm, which had moved for summary judgment arguing full payment according to the workers' compensation fee schedule. The Civil Court initially granted State Farm's motion. On appeal, NYS Acupuncture, P.C. contended that the fee schedule reductions were improper. The Appellate Term, Second Department, affirmed the prior ruling, finding that State Farm adequately demonstrated it had fully compensated the plaintiff for acupuncture services based on the applicable workers' compensation fee schedule for services performed by chiropractors, referencing Great Wall Acupuncture, P.C. v Geico Ins. Co.

Workers' Compensation Fee ScheduleNo-Fault BenefitsAcupuncture ServicesChiropractorsSummary JudgmentAppellate ReviewInsurance DisputeFee Schedule ReductionAssigned BenefitsMedical Billing
References
1
Case No. MISSING
Regular Panel Decision

State Farm Mutual Automobile Insurance Companies v. Brooks

This action arises from an alleged overpayment of no-fault benefits by State Farm to James Brooks. Brooks, injured in an automobile accident, received lost earnings benefits from State Farm, but was later furloughed from his job due to lack of work, not his injury, yet continued to receive full benefits. State Farm sought to recover the alleged overpayment, arguing an insurance regulation (11 NYCRR 65.6 (n) (2) (vi)) required a reduction to unemployment benefits if the position would have been lost regardless of the accident. The court, in a case of first impression, found this regulation invalid as applied to Brooks, conflicting with the Insurance Law's purpose of compensating for actual economic loss. Consequently, summary judgment was granted in favor of the defendant, James Brooks.

No-fault insuranceAutomobile accidentOverpayment of benefitsLost earningsUnemployment benefitsInsurance Law interpretationSummary judgmentStatutory conflictRegulation validityEconomic loss
References
13
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