Claim of Pache v. Aviation Volunteer Fire Co.
The Workers’ Compensation Board granted benefits to the widow of a fire chief who died of a heart attack, finding an implied contract of coverage under Volunteer Firefighters’ Benefit Law § 30 (2) between Aviation Volunteer Fire Company and the City of New York. The City appealed, contending there was no evidence of FDNY Commissioner approval for such a contract and insufficient proof of its formation. The court affirmed the Board’s decision, holding that the City Charter provisions did not exclusively assign contracting authority to the Commissioner and that substantial evidence supported the Board's finding of an implied-in-fact contract, partly due to the City's failure to produce a knowledgeable employee. The court declined to consider a new argument regarding General City Law § 16-a.