Matter of Pellicci v. Republic Aviation Corp., 49 N.Y.2d 389 (1980)

A claimant with a prior work-related permanent partial disability is entitled to continued workers’ compensation benefits even during confinement in a psychiatric ward for the criminally insane, provided the underlying disability persists.

Summary

This case addresses whether a claimant with a pre-existing work-related disability should continue receiving workers’ compensation benefits while confined to a psychiatric ward after being acquitted of a crime due to insanity. The New York Court of Appeals held that such confinement does not automatically preclude the claimant from receiving benefits, as the purpose of workers’ compensation is to protect workers from hardship due to injury, and subsequent mental illness shouldn’t negate those benefits if the original disability continues. Suspending benefits could discourage treatment and worsen the worker’s condition.

Facts

The claimant suffered a back injury in 1959 while employed in New York, and was awarded workers’ compensation benefits for a permanent partial disability. In 1976, while in Italy, he was arrested for fatally shooting two people. An Italian court declared him not responsible for his actions due to total insanity at the time of the crime and ordered him committed to a hospital for the criminally insane for at least ten years.

Procedural History

The employer and its insurance carrier sought to suspend the claimant’s workers’ compensation benefits during his confinement. The Workers’ Compensation Board granted the suspension. The Appellate Division reversed, holding that the claimant was entitled to continued benefits. The New York Court of Appeals affirmed the Appellate Division’s decision.

Issue(s)

Whether a claimant with a prior work-related permanent partial disability is entitled to continue receiving workers’ compensation benefits during the period he or she is confined to a psychiatric ward after being acquitted of a crime due to insanity.

Holding

Yes, because the purpose of workers’ compensation is to protect workers from hardship caused by work-related injuries. Suspending benefits due to subsequent mental illness would compound the hardship and could discourage the claimant from seeking necessary treatment, and the claimant’s underlying disability continued to exist.

Court’s Reasoning

The court emphasized the broad purpose of the Workers’ Compensation Law, which is to protect workers from economic hardship resulting from work-related injuries. The court reasoned that denying benefits to a claimant solely because of subsequent mental illness would not further the goals of the law. In fact, the court noted that mental illness often increases the need for such benefits. The court distinguished this situation from cases where benefits are denied due to criminal conviction, because in this case, the claimant was acquitted due to insanity, meaning that he was found not responsible for his actions. The court cited Matter of Papkoff v. Feldman, stating that there is “no basis, in authority or in reason, for [the] unqualified conclusion that a claimant may not collect payments awarded to him for permanent partial disability unless he is in the labor market. The fortuitous circumstance that a claimant who has sustained a permanent partial disability is subsequently hospitalized… should not inure to the benefit of the carrier while the physical and industrial disability and the loss of wage-earning capacity on which the award was bottomed still continue.” The court explicitly rejected the argument that the claimant’s commitment was the equivalent of a criminal conviction.