Matter of the Claim of Ardolino, 414 N.E.2d 873 (N.Y. 1980)

A collective bargaining agreement can validly limit an employer’s statutory right to reimbursement from a worker’s compensation award, provided the limitation is explicitly stated in the agreement.

Summary

This case concerns a school board seeking reimbursement from a workers’ compensation award paid to a teacher injured on the job. The teacher’s union argued that a collective bargaining agreement limited the board’s reimbursement to the workers’ compensation salary allowance for the weeks the teacher received her regular salary. The court held that the agreement did not sufficiently express an intent to limit the board’s statutory right to full reimbursement. The dissent argued that the contractual language clearly limited reimbursement and should be enforced according to its plain meaning.

Facts

A teacher, Ardolino, was injured on school premises and received a workers’ compensation award for the injury. The City of Buffalo Board of Education, her employer, continued to pay her full salary during her disability, as per a collective bargaining agreement. The Board sought reimbursement from Ardolino’s workers’ compensation award for the salary it paid her during her disability.

Procedural History

The Workers’ Compensation Board ruled in favor of the school board, allowing full reimbursement. The union appealed, arguing the collective bargaining agreement limited the reimbursement amount. The Court of Appeals affirmed the Board’s decision, finding no clear contractual limitation on the employer’s right to reimbursement.

Issue(s)

Whether a provision in a collective bargaining agreement stating that the “salary allowance paid the teacher under Workmen’s Compensation will be assigned to the Board” operates as a limitation on the employer’s statutory right to full reimbursement from a workers’ compensation award.

Holding

No, because the language in the collective bargaining agreement did not explicitly demonstrate an intent to limit the employer’s statutory right to reimbursement from the worker’s compensation award.

Court’s Reasoning

The court reasoned that an employer’s right to reimbursement under the Workers’ Compensation Law is a statutory right, and any contractual modification of that right must be expressed in clear and unambiguous terms. The language in the collective bargaining agreement, which stated, “salary allowance paid the teacher under Workmen’s Compensation will be assigned to the Board,” was deemed insufficient to demonstrate a clear intent to limit the board’s reimbursement right. The court interpreted the provision as merely addressing the mechanics of how the board would receive the reimbursement, not the extent of the reimbursement itself. The court emphasized that absent an express limitation, the employer retains its full statutory right to reimbursement. The dissent argued that the language should be interpreted according to its plain meaning, which, in the dissent’s view, clearly limited the employer’s reimbursement to the weekly salary allowance payable under workers’ compensation. The dissent further contended that the majority’s interpretation rendered the contractual references to the right of reimbursement meaningless. Judge Gabrielli stated in his dissent, “As is evident from its language, this provision was intended to completely regulate the relationship between the board and a teacher who sustains a job-related injury…and limits the employer’s statutory right of reimbursement to the weekly salary allowance payable under workers’ compensation.”