82 N.Y.2d 809 (1993)
The standard for mental incompetency sufficient to toll the statute of limitations for filing a workers’ compensation claim requires an overall inability to function in society and protect one’s legal rights, not merely an inability to comprehend the basis for the claim.
Summary
Cerami filed a workers’ compensation claim in 1980 for a mental breakdown allegedly caused by stressful working conditions that led to his 1967 resignation. The claim was filed after the two-year statute of limitations. Cerami argued that his mental incompetency tolled the statute of limitations. The Workers’ Compensation Board denied the toll, finding Cerami competent to file a claim in 1967. The Appellate Division reversed, holding that the relevant determination was whether Cerami could comprehend the premise for his claim. The Court of Appeals reversed the Appellate Division, holding that the standard for mental incompetency requires an overall inability to function in society, not just an inability to understand the basis for the claim.
Facts
Cerami resigned from his position as a cosmetology instructor with the City of Rochester School District in 1967. In 1980, Cerami filed a workers’ compensation claim, alleging a mental breakdown caused by stressful working conditions. The Workers’ Compensation Law requires claims to be submitted within two years of the accident giving rise to the claim. Cerami argued that Section 115 of the Workers’ Compensation Law tolled the limitations period because he was mentally incompetent.
Procedural History
The Workers’ Compensation Board determined that the Section 115 toll was inapplicable because Cerami was competent to file a claim in 1967. The Appellate Division reversed, holding that the relevant determination was whether Cerami could comprehend the premise for his claim. The Court of Appeals reversed the Appellate Division and reinstated the Board’s decision.
Issue(s)
Whether the Appellate Division erred in defining mental incompetency for the purpose of tolling the statute of limitations under the Workers’ Compensation Law as requiring only an inability to comprehend the premise for the claim, rather than an overall inability to function in society and protect one’s legal rights.
Holding
No, because the definition of mental incompetency for tolling the statute of limitations under the Workers’ Compensation Law requires an overall inability to function in society and protect one’s legal rights, as established in McCarthy v. Volkswagen of Am., not merely an inability to comprehend the basis for the claim.
Court’s Reasoning
The Court of Appeals rejected the Appellate Division’s definition of mental incompetency. The court relied on McCarthy v. Volkswagen of Am., which construed CPLR 208, and held that the insanity toll applies only to those individuals who are unable to protect their legal rights because of an overall inability to function in society. The court reasoned that the same analysis should be applied to the Workers’ Compensation Law’s tolling provision, which constitutes that enactment’s own “statute of repose.” The court emphasized that the task of determining mental incompetency is a pragmatic one, requiring consideration of all surrounding facts and circumstances relevant to the claimant’s ability to safeguard his or her legal rights. The Court stated that the Workers’ Compensation Board is the proper arbiter of such a determination, and the role of the courts is simply to determine whether the Board’s determination is supported by substantial evidence. The Court found that the Board applied the correct legal standard and that its determination was supported by substantial evidence, noting that Cerami had applied for and obtained employment, consulted with attorneys, and filed discrimination complaints during the pertinent period. As the Court noted referencing McCarthy v Volkswagen of Am., the insanity toll is available “to only those individuals who are unable to protect their legal rights because of an over-all inability to function in society” (id., at 548).