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Matter of Bodenmiller v. DiNapoli

Citations: 142 A.D.3d 752; 36 N.Y.S.3d 833Docket: 522491

Court: Appellate Division of the Supreme Court of the State of New York; August 25, 2016; New York; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In this case, a police officer with the Suffolk County Police Department sought accidental disability retirement benefits following an injury sustained in the line of duty. The officer's application was denied by the State Comptroller, who concluded that the incident did not meet the definition of an 'accident' under the applicable Retirement and Social Security Law. The officer requested a hearing to challenge the denial, but the Hearing Officer upheld the Comptroller's determination, finding it was supported by substantial evidence. Upon judicial review, the court identified an error in the legal standard applied by the Hearing Officer, who had merely assessed the evidence rather than conducting a comprehensive redetermination of the application. As a result, the court annulled the Comptroller's decision and remitted the matter for a new hearing, requiring adherence to the correct legal standards. No costs were awarded in this proceeding.

Legal Issues Addressed

Definition of 'Accident' under Retirement and Social Security Law

Application: The State Comptroller denied the application for accidental disability retirement benefits, determining that the incident did not meet the statutory definition of an 'accident.'

Reasoning: His application for benefits was denied by the State Comptroller, who determined that the incident did not qualify as an 'accident' under the Retirement and Social Security Law.

Judicial Review and Standards of Evidence

Application: The court found that the Hearing Officer did not properly apply the legal standard necessary for reviewing evidence, as they only assessed the evidence instead of conducting a full redetermination.

Reasoning: Upon review, the court found that the Hearing Officer had applied an incorrect legal standard by only assessing the evidence rather than conducting a full redetermination of the application.

Remittal for Rehearing

Application: The court annulled the Comptroller's determination and remitted the case for a new hearing because of the misapplication of the law.

Reasoning: This misapplication of the law warranted annulment of the Comptroller’s determination. Consequently, the case has been remitted to the Comptroller for a new hearing consistent with the court's findings.