Liberty Mutual Insurance v. Newman
Plaintiff insurer, Liberty Mutual Insurance Company, mistakenly paid $9,805.66 to defendant Ruth Newman, intended for an aggregate trust fund related to her deceased husband's workers' compensation benefits. After forwarding the correct payment to the fund, Liberty Mutual sought restitution from Newman, who refused. The Workers' Compensation Board declined to intervene, stating no recourse existed under the Workers' Compensation Law for the error. Special Term initially granted summary judgment to Liberty Mutual. On appeal, the judgment was modified, with the Appellate Division agreeing it was a mistake of fact, not an overpayment of benefits, thus affirming the denial of Newman's summary judgment motion. However, the case was remitted to Special Term for a hearing to determine if ordering full restitution would cause a detrimental change in Newman's position regarding her benefits, and clarified that interest and costs should not be awarded against her.