Warshawsky v. DiNapoli
Philip Warshawsky, a unified court officer, sought accidental disability retirement benefits from the New York State and Local Employees’ Retirement System due to heart disease. His application was initially denied based on the Retirement System's interpretation that he failed to prove an "accident" under Retirement and Social Security Law § 605-a, despite his claim under the "Heart Bill" provision, § 605-b. Warshawsky argued that § 605-b establishes a presumption of accidental causation for heart conditions in uniformed court officers, rendering proof of a specific accident unnecessary. The court agreed with Warshawsky, finding that the Retirement System's interpretation of § 605-b was an error of law and irrational. The court annulled the denial and remitted the matter to the Retirement System for reconsideration, affording Warshawsky the benefit of the statutory presumption.