Currie v. Town of Davenport, 37 N.Y.2d 472 (1975)
In workers’ compensation cases, the Workmen’s Compensation Board is not bound to accept the opinion of any one expert, and is free to choose which expert testimony it finds most credible, especially when the opinions are based on inferences of fact rather than direct observation.
Summary
Vernon Currie, an employee of the Town of Davenport with a history of heart disease and diabetes, died while carrying a can of water at work. The Workmen’s Compensation Board initially denied his widow’s claim for benefits, finding his death was due to natural causes. The Appellate Division reversed, but the Court of Appeals reversed the Appellate Division and reinstated the Board’s original decision. The Court held that the Board was entitled to weigh the conflicting medical expert opinions and accept the opinions that Currie’s death was the result of his pre-existing conditions, not his work.
Facts
Vernon Currie, 65, was last seen carrying a five-gallon can of water at his job at a landfill. He had a long history of arteriosclerotic heart pathology and diabetes, requiring medication and hospitalizations. He had suffered a heart attack in 1967, limiting him to part-time, light work. After being seen carrying water, he was found dead an hour later.
Procedural History
The Workmen’s Compensation Board initially denied the claim. The Appellate Division reversed, holding that substantial evidence to sustain the Board’s finding was lacking. The Board then made an award against the employer, holding the Special Disability Fund liable. The employer appealed directly from that decision, bringing up for review the Appellate Division’s order.
Issue(s)
Whether there was sufficient evidence to support the Workmen’s Compensation Board’s finding that Vernon Currie’s death was due to natural causes rather than an accidental injury within the meaning of the Workmen’s Compensation Law.
Holding
Yes, because the Workmen’s Compensation Board is entitled to weigh conflicting medical expert opinions and accept the opinions that the employee’s death was the result of pre-existing conditions, not his work.
Court’s Reasoning
The court emphasized that the dispute was less about the facts of Currie’s death and more about the inferences drawn from those facts, particularly regarding the medical evidence. Three medical experts offered opinions: Dr. VandenBerg, Currie’s personal physician, testified that carrying the water could have contributed to Currie’s death, but admitted a myocardial infarction could have occurred independently due to Currie’s pre-existing conditions. Dr. Walters, a cardiac specialist, attributed the death to Currie’s pre-existing arteriosclerotic heart disease. Dr. Wilbur, the medical examiner, concluded the death was due to cardiac arrest resulting from heart disease and uncontrolled diabetes. The court noted that the referee and the Board were entitled to weigh the opinions of the experts, and were “free to choose those it credits and reject those it does not”. The court stated, “It is axiomatic that a trier of facts may accept or reject the opinion of an expert just as he may that of a layman and, for the most part, on similar principles.” The court also noted that the Board’s finding indicated that the death was not work-related and stemmed from the “ordinary wear and tear of life.” The court held that to rule otherwise would mean any heart attack occurring at work would be compensable, which is not the law. The case clarifies the board’s discretion in evaluating expert testimony, particularly when based on inferences and pre-existing conditions, affecting future workers’ compensation claims involving heart conditions.