Matter of Nicholas v. Santini Bros., 17 N.Y.2d 245 (1966)
A coronary occlusion or thrombosis is compensable as an industrial accident under worker’s compensation if it results from excessive strain during work, even with a pre-existing condition, and the Workmen’s Compensation Board’s choice between conflicting expert opinions on causation is conclusive if supported by substantial evidence.
Summary
The New York Court of Appeals reversed the Appellate Division’s decision, reinstating the Workmen’s Compensation Board’s award to the claimant. The decedent, a warehouse helper with a pre-existing heart condition, died after performing strenuous work involving heavy lifting. Conflicting expert opinions were presented regarding causation, with the claimant’s expert attributing the death to the physical exertion. The Court of Appeals emphasized that the Board’s factual finding of causal connection, based on substantial evidence (claimant’s expert testimony), is binding, even if other causes were possible. This case clarifies that worker’s compensation can cover heart attacks precipitated by work-related strain, despite pre-existing conditions, and underscores the Board’s role in resolving expert disputes.
Facts
The decedent, a 28-year-old warehouse helper, worked for Santini Brothers. On September 12, 1955, he performed tasks including loading furniture (mattresses, bedsprings, and a mirror) into an Army van, some items requiring two people to lift. Around 8:30 a.m., while disassembling a bed frame, he collapsed and died. An autopsy revealed the cause of death as coronary sclerosis and endarteritis obliterans, indicating a pre-existing heart condition. The employer stipulated that he lifted weights ranging from 5 to 150 pounds that morning.
Procedural History
The Workmen’s Compensation Board initially awarded benefits to the claimant. The Appellate Division, Third Department, reversed the Board’s decision, finding a lack of substantial evidence of causal connection. The claimant then appealed to the New York Court of Appeals.
Issue(s)
Whether there was substantial evidence to establish a causal relation between the work performed by the decedent and his death, considering his pre-existing heart condition and conflicting expert opinions.
Holding
Yes, because the Workmen’s Compensation Board’s finding of causal connection was supported by substantial evidence, namely the testimony of the claimant’s medical expert, and the Board is entitled to choose between conflicting expert opinions.
Court’s Reasoning
The Court of Appeals emphasized that a coronary occlusion or thrombosis is compensable if it results from excessive strain at work, even with a pre-existing pathology. The court cited Matter of Schechter v. State Ins. Fund, 6 N.Y.2d 506 (1959), stating: “There is no longer any doubt that a coronary occlusion or thrombosis is compensable as an industrial accident provided it is the resultant of excessive strain in the performance of one’s work and this is true even though there be a pre-existing pathology which also contributes to the injury.” The court acknowledged conflicting expert opinions but reaffirmed the Board’s fact-finding authority, citing Matter of Palermo v. Gallucci & Sons, 5 N.Y.2d 529 (1959): “The selection of either [of the conflicting expert opinions] is an exercise of fact-finding power which is entirely within the province of the Board and outside the limited jurisdiction of this court.” Even though the claimant’s expert conceded other potential causes, his opinion that the work could have caused the death constituted substantial evidence, as per Matter of Ernest v. Boggs Lake Estates, 12 N.Y.2d 414 (1963). The court deferred to the Board’s expertise in weighing the evidence and determining causation. Therefore, the Appellate Division erred in substituting its judgment for that of the Board. This case underscores the broad scope of worker’s compensation coverage for heart-related incidents and the deference appellate courts give to the Board’s factual findings.