Matter of Estate of Marguerite G. McFadden v. A. Russo Wrecking, Inc., 80 N.Y.2d 674 (1993)
Under Workers’ Compensation Law § 10(1), injuries sustained during voluntary participation in off-duty athletic activities are not compensable unless the employer requires participation, compensates the employee, or otherwise sponsors the activity, and the activity must be part of the employee’s work-related duties.
Summary
This case concerns a claim for workers’ compensation benefits following the death of an accountant who suffered a fatal heart attack while bowling on a team sponsored by a client. The Workers’ Compensation Board denied the claim, citing Workers’ Compensation Law § 10(1), which excludes compensation for injuries sustained during voluntary off-duty athletic activities. The Court of Appeals affirmed, holding that the bowling activity was not part of the employee’s work-related duties, and the employer neither required nor compensated the employee for participating, nor did the employer sponsor the activity.
Facts
The decedent, an accountant, bowled in a Monday night league on a team sponsored by Tom Cardinal, a client of his firm. The decedent and Cardinal were friends and discussed business before and after bowling. No other employees from either firm participated. On the night of his death, Cardinal picked up the decedent, they discussed business, and then bowled three games. The decedent suffered a cardiovascular collapse and died shortly after. The Workers’ Compensation Board focused on whether the activity fell under the statutory exclusion for voluntary athletic activities.
Procedural History
The Workers’ Compensation Law Judge initially ruled on the case. The Workers’ Compensation Board reversed the Law Judge’s decision, denying the claim based on Workers’ Compensation Law § 10(1). The Appellate Division upheld the Board’s decision. The Court of Appeals granted leave to appeal and affirmed the Appellate Division’s order.
Issue(s)
Whether the decedent’s death, occurring during a voluntary, off-duty athletic activity (bowling), is compensable under the Workers’ Compensation Law, specifically considering the restrictions outlined in Workers’ Compensation Law § 10(1)?
Holding
No, because the bowling activity was a voluntary, off-duty athletic activity not part of the employee’s work-related duties, and the employer did not require, compensate, or sponsor the activity as outlined in Workers’ Compensation Law § 10(1).
Court’s Reasoning
The Court reasoned that Workers’ Compensation Law § 10(1) explicitly bars compensation for injuries sustained during voluntary off-duty athletic activities unless the employer requires participation, compensates the employee, or otherwise sponsors the activity. The Court emphasized that the activity must constitute part of the employee’s work-related duties. The Court distinguished between activities that are merely work-related and those that are part of an employee’s actual job duties, stating, “Were the test simply whether an activity was work-related, the statutory bar and the Legislature’s intent would be defeated by an open-ended interpretation.” The Court found no evidence that the employer required or compensated the decedent for bowling, nor did it formally sponsor the activity. Mere knowledge or acquiescence by the employer was deemed insufficient to constitute sponsorship. The Court highlighted the legislative intent behind the 1983 amendment to section 10, which aimed to narrow the standards for compensable work-related sports injuries and prevent awards based on insufficient employer involvement. The Court quoted the legislative memorandum, stating that the amendment “will not change the liability of the employer when participation in an activity is overtly encouraged by the employer.” The Court concluded that the Board’s determination was supported by substantial evidence, and the activity did not fall within the exceptions permitting compensation.