McCambridge v. McGuire, 62 N.Y.2d 563 (1984)
For a police officer’s injury to qualify as an ‘accidental injury’ entitling them to an accident disability pension, the injury must result from a sudden, fortuitous mischance that is unexpected, out of the ordinary, and injurious in impact, not merely from performing routine duties.
Summary
This case clarifies the definition of “accidental injury” under the New York City Administrative Code for police officers seeking accident disability pensions. The Court of Appeals reversed the Appellate Division’s dismissal of petitions from two officers who sustained injuries in the line of duty. The court held that both officers’ injuries stemmed from identifiable accidental events – one officer falling after losing his balance and the other slipping on wet pavement – and were thus eligible for accident disability pensions. The court distinguished these incidents from injuries resulting from the performance of routine duties, even if those duties are inherent in the job.
Facts
Detective McCambridge injured his knee when he lost his balance and fell while steadying himself on another detective’s shoulder. This occurred because the other detective unexpectedly moved. Surgical repair was required, and McCambridge was permanently disabled.
Patrolman Knight slipped on wet pavement while entering his patrol car, injuring his elbow. He also required surgery and was permanently disabled. The Medical Board determined his injury was accidental.
Procedural History
The Board of Trustees denied accident disability pensions to both officers, awarding ordinary disability pensions instead, by a 6-6 vote.
The Appellate Division affirmed the dismissal of both petitions, citing Matter of Lichtenstein v Board of Trustees, stating that an injury is not accidental if it occurs without an unexpected event during ordinary job duties.
The Court of Appeals granted leave to appeal and reversed the Appellate Division’s orders.
Issue(s)
Whether the injuries sustained by Detective McCambridge and Patrolman Knight qualify as “accidental injuries” under the Administrative Code of the City of New York, entitling them to accident disability pensions, or whether they were injuries sustained during routine duties and thus not covered.
Holding
Yes, because both officers’ injuries resulted from sudden, unexpected events (a loss of balance and a slip on wet pavement), not from the routine performance of their duties. The Board of Trustees applied an erroneous legal standard in denying the pensions.
Court’s Reasoning
The Court of Appeals emphasized that to qualify for accident disability retirement, an injury must be the “natural and proximate result of an accidental injury received in…city-service” (Administrative Code of City of New York, § B18-43.0). The court clarified that not every line-of-duty injury qualifies, but only those resulting from a “‘sudden, fortuitous mischance, unexpected, out of the ordinary, and injurious in impact’” (Matter of Lichtenstein v Board of Trustees, 57 NY2d 1010, 1012).
The court distinguished the present cases from those involving injuries sustained while performing routine duties without an unexpected event, such as back strains from putting a tire in a trunk or lifting trash cans.
The critical factor was the “precipitating accidental event” – the loss of balance in McCambridge’s case and the slip on wet pavement in Knight’s case.
The court noted that while the Board of Trustees’ decisions are typically binding after a 6-6 vote, the court can set aside a denial of benefits when the applicant is entitled to them as a matter of law. Here, the Board applied an erroneous legal standard by focusing on the officers’ job assignments rather than the unexpected events causing the injuries. The court explicitly stated, “In each case we conclude as a matter of law that there was an accident.”