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Keywords

workers' compensationnovationrespondent
workers' compensationnovationrespondent

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Keeley, Matter of

Facts

Claimant, a teacher employed by respondent Jamestown City School District, was assigned to work at the School District's middle school sometime in 1988. In the summer of 1992, the middle school underwent substantial renovations, including repainting of walls and ceilings, replacement of doorways and installation of new carpeting. When claimant returned to work in September 1992, the renovations were not complete and he began to experience various symptoms including, inter alia, tingling and numbness in his extremities, burning eyes, sinus congestion, fatigue, muscle cramps, fluctuations in body temperature and irritability. In October 1992, he sought medical attention for these symptoms and stopped working. The School District subsequently filed a C-2 form indicating that claimant's disability was due to claimed exposure to chemicals at the middle school.

Claimant, a teacher employed by respondent Jamestown City School District, was assigned to work at the School District's middle school sometime in 1988. In the summer of 1992, the middle school underwent substantial renovations, including repainting of walls and ceilings, replacement of doorways and installation of new carpeting. When claimant returned to work in September 1992, the renovations were not complete and he began to experience various symptoms including, inter alia, tingling and numbness in his extremities, burning eyes, sinus congestion, fatigue, muscle cramps, fluctuations in body temperature and irritability. In October 1992, he sought medical attention for these symptoms and stopped working. The School District subsequently filed a C-2 form indicating that claimant's disability was due to claimed exposure to chemicals at the middle school.

Issue

Did the claimant sustain a causally related disability that would entitle him to workers' compensation benefits?

Did the claimant sustain a causally related disability that would entitle him to workers' compensation benefits?

Rule

The burden of establishing a causal relationship between employment and a disability rests with the claimant, who must do so by competent medical evidence.

The burden of establishing a causal relationship between employment and a disability rests with the claimant, who must do so by competent medical evidence.

Analysis

The court found that the Workers' Compensation Board was permitted to resolve conflicts in the evidence presented. Although certain medical experts diagnosed the claimant with conditions related to chemical exposure, other medical experts provided contrary opinions. The court concluded that substantial evidence supported the Board's finding that the claimant failed to satisfy his burden of proving that his disability was causally related to his employment.

The court found that the Workers' Compensation Board was permitted to resolve conflicts in the evidence presented. Although certain medical experts diagnosed the claimant with conditions related to chemical exposure, other medical experts provided contrary opinions. The court concluded that substantial evidence supported the Board's finding that the claimant failed to satisfy his burden of proving that his disability was causally related to his employment.

Conclusion

The appellate court affirmed the board's decision, concluding that the claimant did not prove a causal relationship between his disability and his employment.

The appellate court affirmed the board's decision, concluding that the claimant did not prove a causal relationship between his disability and his employment.

Who won?

The New York Workers' Compensation Board prevailed in the case because the court found substantial evidence supporting the Board's conclusion that the claimant failed to prove a causally related disability.

The New York Workers' Compensation Board prevailed in the case because the court found substantial evidence supporting the Board's conclusion that the claimant failed to prove a causally related disability.

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