Matter of Meyer v. Board of Trustees, 60 N.Y.2d 139 (1983)

An accident that precipitates the development of a latent condition or aggravates a pre-existing condition can be a cause of disability entitling a claimant to accident disability benefits.

Summary

Meyer, a stationary fireman, sought accident disability benefits after an explosion at work caused head trauma, leading to physical and psychological issues. The Medical Board denied accident disability benefits, finding the accident merely “precipitated” his psychological issues, not caused them. The Court of Appeals reversed, holding that an accident that precipitates or aggravates a pre-existing condition can be a cause of disability under the Administrative Code. The Court emphasized that the Board applied an incorrect standard of causation when it distinguished between precipitating and causing an injury.

Facts

Meyer, a stationary fireman, was working when an explosion occurred, causing him to strike his head. He experienced headaches, dizziness, and ringing in his ears immediately following the incident. Multiple doctors diagnosed him with hearing loss, tinnitus, dizziness, and headaches related to the explosion. Later, a psychiatrist diagnosed Meyer with traumatic neurosis with depression causally related to the accident. A psychiatric consultant for the Medical Board found that while Meyer’s symptoms were temporally related to the accident, the accident merely precipitated, rather than caused, the symptoms.

Procedural History

Meyer applied for accident disability retirement, which was initially denied by the Medical Board and subsequently by the Board of Trustees. He then commenced a proceeding challenging the denial. Special Term rejected his claim, and the Appellate Division affirmed. The Court of Appeals heard the appeal as of right due to a dissent in the Appellate Division.

Issue(s)

Whether the Board of Trustees applied the correct standard of causation in denying Meyer’s application for accident disability retirement benefits, considering that his psychological disability was deemed to be precipitated, but not directly caused, by the work-related accident.

Holding

Yes, because the causation rule both in tort law and under the workers’ compensation statute is that an accident which produces injury by precipitating the development of a latent condition or by aggravating a preexisting condition is a cause of that injury.

Court’s Reasoning

The Court of Appeals found that the Medical Board applied an incorrect legal standard. The court stated, “inasmuch as it is well-established law that an accident which precipitates an injury may be a proximate cause of that injury, and the governing statute requires only that petitioner’s disability be ‘a natural and proximate result of an accidental injury’ (Administrative Code § B3-40.0), the aforementioned report seems contradictory in law.” The Court cited established tort and worker’s compensation law, noting, “[t]he causation rule both in tort law and under the workers’ compensation statute is that an accident which produces injury by precipitating the development of a latent condition or by aggravating a preexisting condition is a cause of that injury.” The court found no meaningful distinction between an accident ‘causing’ a disability and an accident ‘precipitating’ a disability. The court explicitly cited a number of cases, including Matter of Benware v Benware Creamery, 16 NY2d 966, McCahill v New York Transp. Co., 201 NY 221, and Bartolone v Jeckovich, 103 AD2d 632. Because the Board relied on a flawed understanding of causation, the Court remitted the matter for reconsideration. The court emphasized that an accident exacerbating an underlying condition can be sufficient for disability benefits, assuming that evidence is accepted.