Matter of Perez v. SN Gold Corp.
In 1991, while working for a gold jewelry manufacturer, the claimant was robbed at gunpoint. A 2002 Workers' Compensation Law Judge (WCLJ) decision found a work-related injury of posttraumatic stress disorder (PTSD), which was affirmed by the Workers' Compensation Board. Following a 2015 hearing, a WCLJ determined that the claimant continued to suffer from PTSD with a temporary marked partial disability, awarding weekly compensation. The Board upheld this decision, leading to the employer's appeal. The court affirmed the Board's determination, finding substantial evidence from psychologists Ranita Fooks and Elina Spektor supported a further causally-related disability. The court also rejected the employer's contention that an independent medical examination (IME) report was wrongly deemed inadmissible due to noncompliance with Workers’ Compensation Law § 137 (1) (a), clarifying that partial compliance is not substantial compliance.