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Roach v. McCall

Citations: 251 A.D.2d 941; 674 N.Y.S.2d 875; 1998 N.Y. App. Div. LEXIS 7762

Court: Appellate Division of the Supreme Court of the State of New York; June 25, 1998; New York; State Appellate Court

Narrative Opinion Summary

In a CPLR article 78 proceeding, a tow-truck operator employed by the Suffolk County Police Department challenged the Comptroller’s denial of his application for accidental disability retirement benefits. The petitioner cited two incidents of back injury: one from closing a stuck impound yard gate, and another from pushing a disabled vehicle. The Comptroller determined that neither incident qualified as an 'accident' under Retirement and Social Security Law § 605(b)(3), as both events were within the petitioner’s regular job duties. The court upheld this decision, emphasizing that an 'accident' requires an unexpected event outside the ordinary course of employment. The petitioner's acknowledgment of the gate's tendency to stick and the routine nature of handling obstacles in his work supported the conclusion that these were not unexpected incidents. Consequently, the court found substantial evidence backing the Comptroller's denial of benefits, leading to the dismissal of the petition without costs.

Legal Issues Addressed

Definition of 'Accident' under Retirement and Social Security Law § 605(b)(3)

Application: The court applied the definition of an 'accident' as an unexpected event outside the ordinary course of employment, which was not met by the incidents described by the petitioner.

Reasoning: The court upheld this determination, defining an 'accident' as an unexpected event outside the ordinary course of employment.

Substantial Evidence Standard in Administrative Reviews

Application: The court found that there was substantial evidence supporting the Comptroller's decision to deny the benefits, as the petitioner failed to demonstrate that the injuries were caused by unexpected events.

Reasoning: The court found substantial evidence supporting the Comptroller's decision, confirming the determination and dismissing the petition without costs.