Leone v. Oneida County Sheriff’s Dept., 76 N.Y.2d 850 (1990)
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Workers’ Compensation Law § 30(3) does not permit an employer to offset payments made for medical expenses under General Municipal Law § 207-c against a schedule award granted under Workers’ Compensation Law § 15(3).
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Summary
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A Deputy Sheriff, injured in the line of duty, received full wages and medical expenses from Oneida County under General Municipal Law § 207-c. The County, a self-insured workers’ compensation provider, also covered its police officers under a workers’ compensation plan. The claimant received a schedule award for permanent partial loss of use of his left leg. The Workers’ Compensation Board credited the County for wages paid under § 207-c but disallowed credit for medical expenses against the schedule award. The County argued Workers’ Compensation Law § 30(3) authorized this credit. The Court of Appeals affirmed the Board’s decision, holding that medical expense payments under § 207-c cannot be credited against schedule awards under § 15(3), as it would not further the legislative purpose of preventing duplicate salary benefits.
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Facts
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Claimant, a Deputy Sheriff employed by Oneida County Sheriff’s Department, was injured in a line-of-duty accident.r
As required by General Municipal Law § 207-c (1), the County paid the claimant his full wages for 4.8 weeks of total disability, plus $241.58 in medical expenses.r
The County covered its police officers under a workers’ compensation plan and was self-insured for that purpose.r
Claimant filed a claim with the State Workers’ Compensation Board and was awarded partial wage replacement benefits for temporary total disability.r
He also received a schedule award under Workers’ Compensation Law § 15 (3) for permanent partial loss of use of his left leg.r
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Procedural History
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The Workers’ Compensation Board credited the County for wages paid to the claimant under General Municipal Law § 207-c but disallowed any credit for medical expenses paid on claimant’s behalf.r
The County appealed, arguing Workers’ Compensation Law § 30 (3) authorized a credit for medical expenses against the schedule award.r
The Appellate Division affirmed the Board’s decision.r
The Court of Appeals affirmed the Appellate Division’s order.r
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Issue(s)
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Whether Workers’ Compensation Law § 30(3) allows a county to credit medical expense payments made under General Municipal Law § 207-c against a schedule award granted under Workers’ Compensation Law § 15(3).r
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Holding
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No, because applying Workers’ Compensation Law § 30(3) literally to allow such a credit does not further the legislative purpose of preventing the duplication of salary benefits and would lead to incongruous results.r
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Court’s Reasoning
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The court addressed the County’s argument that the plain language of Workers’ Compensation Law § 30 (3) compels crediting of General Municipal Law § 207-c medical expense payments against Workers’ Compensation Law § 15 (3) schedule awards.r
The court stated that the literal implementation urged by the County does not further the Legislature’s expressed purpose in enacting Workers’ Compensation Law § 30 (3) and would lead to an incongruous result.r
The court reasoned that paying a Workers’ Compensation Law § 15 (3) schedule award and separately paying General Municipal Law § 207-c medical expenses does not duplicate salary benefits, which the statute was designed to prevent.r
The court further noted that it would be anomalous to disadvantage employees in the claimant’s position by allowing a credit against a schedule award for General Municipal Law § 207-c medical expense payments when such a credit is not allowed for Workers’ Compensation Law § 13 payments. The legislative intent behind Workers’ Compensation Law § 30(3) was