New York Law Review

Matter of Meyer v. Board of Trustees, 54 N.Y.2d 335 (1981): Standard of Review for Accidental Disability Benefits Determinations

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Matter of Meyer v. Board of Trustees, 54 N.Y.2d 335 (1981)

When a board of trustees denies accidental disability benefits due to a tie vote, a court can only overturn that decision if the retiree is entitled to the greater benefits as a matter of law, meaning the disability was undeniably the result of a service-related accident.

Summary

Meyer, a police officer, sought accidental disability retirement benefits due to a 1971 car accident. The medical board initially denied his request, then later recommended ordinary disability, and finally accidental disability. The Board of Trustees rejected the final recommendation, citing Meyer’s medical history and the opinion of the chief surgeon, who believed Meyer’s condition was due to arthritis, not the accident. The court held that because the Board’s denial of accidental disability benefits resulted from a tie vote, the denial can only be overturned if the claimant is entitled to accidental disability as a matter of law, which was not the case here.

Facts

  • Meyer, a NYC police officer since 1963, was in a car accident in 1971 and treated for contusions.
  • He returned to full duty after 11 days.
  • In 1979, he applied for accidental disability retirement related to the 1971 accident.
  • The Police Medical Board initially denied the request, citing degenerative changes due to “wear and tear.”
  • The Medical Board later recommended ordinary disability retirement, then accidental disability benefits.
  • The Board of Trustees rejected the accidental disability recommendation.
  • The Chief Surgeon believed Meyer’s condition was from arthritis, not the accident, noting Meyer’s short sick leave and subsequent years of full duty.

Procedural History

  • Meyer commenced an Article 78 proceeding after the Board of Trustees denied accidental disability benefits.
  • Special Term vacated the Board’s determination and ordered accidental disability retirement benefits.
  • The Appellate Division reversed, reinstated the Board’s determination, finding it was not arbitrary.
  • The Court of Appeals affirmed the Appellate Division’s decision.

Issue(s)

  • Whether the Board of Trustees acted properly in denying Meyer accidental disability retirement benefits and granting him only an ordinary disability pension.
  • When the Board of Trustees denies accidental disability benefits because of a tie vote, what is the standard for judicial review of that decision?

Holding

  • No, the Board of Trustees acted properly.
  • The denial of accidental disability benefits can be set aside only if the courts conclude that the retiree is entitled to the greater benefits as a matter of law; otherwise, the decision of the board must stand.

Court’s Reasoning

The court reasoned that while the Medical Board’s determination of disability is binding on the Board of Trustees, the Board of Trustees determines whether the disability resulted from a service-related accident. Ordinarily, the Board’s decision on the cause of disability is upheld unless unsupported by substantial evidence or is arbitrary and capricious.

However, because the Board’s decision resulted from a tie vote, a different standard of review applies, as established in Matter of City of New York v. Schoeck. The court stated that the denial of accidental disability benefits due to a tie vote can be overturned only if the retiree is entitled to the greater benefits as a matter of law. “Unless it can be determined as a matter of law on the record that the disability was the natural and proximate result of a service-related accident, the decision of the board of trustees denying accidental disability benefits as a consequence of a tie vote must stand.”

Based on the record, the court could not conclude that Meyer was entitled to accidental disability benefits as a matter of law. The Chief Surgeon’s opinion and Meyer’s medical history provided credible evidence supporting the Board’s decision. Therefore, the Board of Trustees’ denial was upheld. The key factor is whether the causal connection between the accident and disability is so clear that reasonable minds could not differ.

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