Matter of Galdon v. Robert Basil Inc.
Claimant John Galdon, an autobody technician, filed a workers' compensation claim for a work-related back injury sustained on February 29, 2020. The employer and carrier disputed the claim, primarily citing a lack of timely notice. A Workers' Compensation Law Judge (WCLJ) found sufficient evidence for accident, notice, and causal relationship, awarding benefits, which the Workers' Compensation Board subsequently affirmed. On appeal, the Appellate Division, Third Department, upheld the Board's decision, determining that there was substantial evidence to support the finding that claimant provided adequate verbal notice to his employer shortly after the accident. The court also found substantial evidence for the causal relationship between Galdon's employment and his injury, based on his testimony and the consistent medical opinions of both his treating neurosurgeon, Michael Stoffman, and the carrier's examining neurosurgeon, Richard Kanoff.