88 N.Y.2d 756 (1996)
A Medical Board’s disability determination in a NYCERS case will be sustained unless it lacks a rational basis or is arbitrary and capricious, and the determination will not be disturbed if it is based on some credible evidence.
Summary
Borenstein, an Assistant Deputy Warden, sought accidental disability retirement benefits from the New York City Employees’ Retirement System (NYCERS) after allegedly slipping and falling at work. The Medical Board of NYCERS denied her application, finding she was not medically disabled for city service. The Appellate Division reversed the Supreme Court’s dismissal of Borenstein’s Article 78 proceeding, granting her application. The Court of Appeals reversed, holding that the Medical Board’s determination had a rational basis and was supported by some credible evidence, and the Appellate Division improperly substituted its judgment for that of the Medical Board. This case clarifies the deferential standard of review applied to NYCERS Medical Board determinations.
Facts
Borenstein allegedly slipped on loose carpeting at Rikers Island, injuring her neck, shoulder, back, and right hand/wrist. She was examined by Department of Correction physicians, who diagnosed a sprained right hand and noted neck discomfort. An MRI later revealed a herniated disc. Borenstein’s physician concluded she was unfit for duty. NYCERS Medical Board physicians examined her and found limited motion in her cervical spine, weak left hand grip, and pain in her left paracervical and trapezius muscles, but concluded her complaints did not substantiate a disability claim. Conflicting medical opinions arose regarding the extent of Borenstein’s disability.
Procedural History
The NYCERS Medical Board initially denied Borenstein’s application. After reconsideration, including additional medical reports, the Medical Board reaffirmed its denial. The NYCERS Board of Trustees denied Borenstein’s request. Borenstein commenced a CPLR Article 78 proceeding to annul the determination. Supreme Court dismissed the petition. The Appellate Division reversed, granting Borenstein an accident disability pension. The Court of Appeals reversed the Appellate Division’s order and dismissed the petition.
Issue(s)
Whether the Medical Board’s determination that Borenstein was not medically disabled for the performance of city service lacked a rational basis or was arbitrary and capricious, warranting judicial intervention.
Holding
No, because the Medical Board’s determination was based on some credible evidence and was not arbitrary or capricious. The Appellate Division erred in substituting its judgment for that of the Medical Board.
Court’s Reasoning
The Court of Appeals emphasized that the award of accidental disability retirement benefits is a two-step process: first, the Medical Board determines if the applicant is medically disabled; second, the Board of Trustees evaluates causation. The Medical Board’s finding will be sustained unless it lacks rational basis or is arbitrary or capricious. Ordinarily, the Medical Board’s determination will not be disturbed if it is based on substantial evidence, which, in disability cases, is construed as requiring “some credible evidence.” The Court found that the Medical Board’s determination was based on “some credible evidence.” The Court noted that while the Medical Board considered Borenstein’s subjective complaints, the record showed it went beyond those complaints. The medical evidence, including the MRI, was subject to conflicting interpretations, and the Board had the authority to resolve such conflicts. The Court stated, “[i]n the end, the Appellate Division here did what it should not do: ‘substitute [its] own judgment for that of the Medical Board’.” Because the Appellate Division improperly overturned the Medical Board’s finding regarding disability, it also erred in granting an accident disability pension, which is dependent on a finding of causation as well as disability.