Matter of Galuski v. New York State Division of Military and Naval Affairs
Claimant suffered a work-related back injury and utilized leave credits for her absence, during which she received full wages. A Workers’ Compensation Law Judge (WCLJ) awarded benefits and directed the employer's insurance carrier to reimburse the employer for wages paid. While the carrier timely reimbursed the employer, the employer delayed restoring the claimant's accrued leave credits for nearly a year. The claimant sought to impose a penalty on the employer under Workers’ Compensation Law § 25 (3) (f) for this delay. Both the WCLJ and the Workers’ Compensation Board declined the penalty. The appellate court affirmed, ruling that the cited Workers’ Compensation Law provision for penalties applies when there is a failure to make compensation payments according to the award's terms, and the initial award did not include an obligation for the employer to timely restore leave time to the claimant.