Meyer v. Board of Trustees of the New York City Police Department, 65 N.Y.2d 1005 (1985)
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An accident that precipitates the development of a latent condition or aggravates a preexisting condition is a cause of injury for purposes of determining accident disability benefits.
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Summary
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Petitioner Meyer, a New York City Police officer, sought accident disability retirement benefits after sustaining a line-of-duty injury. The Medical Board recommended ordinary disability retirement, attributing his condition to pre-existing ankylosing spondylitis. The Board of Trustees affirmed this recommendation, despite conflicting medical opinions and questions about the accident’s role as a catalyst. The Court of Appeals reversed, holding that the Board of Trustees failed to properly consider whether the injury precipitated or aggravated a pre-existing condition, as required under the causation standard established in Matter of Tobin v. Steisel.
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Facts
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Officer Meyer injured himself in the line of duty on August 13, 1979. Following the injury, he was examined by an orthopedic consultant, who suggested a link between Meyer’s ankylosing spondylitis and his Crohn’s Disease, which became active after the injury. Meyer applied for accident disability retirement benefits, claiming his injuries permanently incapacitated him. His physician asserted that pain and stiffness in his cervical spine were connected to the August 1979 injury. The Medical Board determined his disability was due to pre-existing ankylosing spondylitis, unrelated to the injury.
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Procedural History
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The Medical Board recommended ordinary disability retirement. The Board of Trustees confirmed the Medical Board’s determination on a tie vote. The Supreme Court annulled the Board’s determination and remanded for a fact-finding hearing. The Appellate Division reversed, reinstated the Board of Trustees’ determination, and dismissed the petition. The Court of Appeals reversed the Appellate Division’s order.
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Issue(s)
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Whether the Board of Trustees properly considered if the officer’s line-of-duty injury precipitated the development of a latent condition or aggravated a pre-existing condition, thereby entitling him to accident disability benefits.
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Holding
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No, because the Board of Trustees failed to adequately address whether the injury either precipitated the development of a latent condition or aggravated a pre-existing condition, which is the proper causation standard for accident disability determinations.
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Court’s Reasoning
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The court relied on Matter of Tobin v. Steisel, which established that an accident that either triggers a latent condition or worsens a pre-existing condition is a cause of injury for determining accident disability. The court found that the Board of Trustees did not properly consider this causation standard. A member of the Board of Trustees, Dr. Robinson, stated that he did not believe the question of whether the injury accelerated the condition was important. The Court of Appeals emphasized the importance of considering conflicting medical opinions and determining whether the accident acted as a catalyst. The court stated, “[I]n light of the conflicting views in the record as to the cause of petitioner’s disabling condition and the apparent failure of the Board of Trustees to address whether the injury precipitated the development of a latent condition or aggravated a preexisting condition, we reverse the order of the Appellate Division and remit the matter to Special Term with directions to vacate the agency determination and to remand the matter to the Board of Trustees for reconsideration in accordance with Matter of Tobin v Steisel.”