Matter of Cabrera v. New York City Hous. Auth.
Joseph Cabrera, the claimant, established a workers' compensation claim for work-related injuries and was subsequently classified with a permanent partial disability. The self-insured employer, New York City Housing Authority, failed to make timely compensation payments, leading to the imposition of a late payment penalty under Workers' Compensation Law § 25 (1) (e). Claimant's counsel sought an award of counsel fees for their role in securing this penalty, but the application was denied by the Workers' Compensation Law Judge, a decision later affirmed by the Workers' Compensation Board. The denial was based on recent amendments to Workers' Compensation Law § 24, which do not provide for additional fees for procuring late payment penalties. The Appellate Division, Third Department, affirmed the Board's decision, citing consistency with prior rulings that underscore the lack of authority to award such counsel fees.