Matter of Dudek v. Victory Markets
This case involves an appeal from a Workers’ Compensation Board decision regarding a claimant’s eligibility to reopen a 1986 work-related knee injury claim. The claimant sustained an initial knee injury in 1986, for which compensation was paid for a brief period. After a subsequent knee injury in 2001 and a knee replacement surgery in 2011, an independent medical examination attributed a majority of the knee replacement to the 1986 injury. The employer argued that liability for the 1986 claim should transfer to the Special Fund for Reopened Cases under Workers’ Compensation Law § 25-a, and further payments were barred by Workers’ Compensation Law § 123, due to the claim being truly closed since 1986. The Workers’ Compensation Board affirmed this position. The Appellate Division affirmed the Board’s decision, finding substantial evidence supported that the 1986 case was truly closed and that the time limits imposed by Workers’ Compensation Law §§ 25-a and 123 applied, thus barring the reopening of the case and further benefits.