NY Court of Appeals Judges Spar Over How to Define the Word 'Act' in Disability Benefits Case
"If the legislature intended to exclude the injuries at issue here, it could have easily drafted the statutory language more restrictively," Associate Justice Paul Feinman wrote for the majority.
November 25, 2019 at 04:57 PM
7 minute read
Judges on the New York Court of Appeals sparred Monday over how the word "act," as in action, should be defined in relation to an injured correction officer, who the court decided, in a rare split reversal, was entitled to special disability benefits over the incident.
The majority, on a 4-3 vote, ruled that a law entitled the injured officer to performance-of-duty disability retirement benefits. Chief Judge Janet DiFiore was among the three judges on the dissenting side.
"If the legislature intended to exclude the injuries at issue here, it could have easily drafted the statutory language more restrictively," Associate Justice Paul Feinman wrote for the majority.
The case was brought against the New York State Comptroller's Office by Patricia Walsh, who was injured when an inmate accidentally fell on her while exiting a transport van. Walsh broke the inmate's fall and ended up with damage to her rotator cuff, cervical spine, and back.
Walsh was represented before the Court of Appeals by Jonathan Edelstein, managing partner at Edelstein & Grossman in Manhattan.
"The kind of accident that happened here where an inmate is drunk or high and takes a fall is the kind of thing that can often happen to a person, and is the kind of thing a correction officer should be protected from," Edelstein said.
It's unclear if the inmate was intoxicated or on drugs at the time, but multiple correction officers testified at the time that she appeared that way. It was difficult for her to stand, Feinman wrote.
Walsh was one of a few correction officers tasked with transporting her from court to the Nassau County Jail in 2012. When they arrived, the inmate took a few steps forward and fell out of the van on to Walsh, who was taken to the hospital. She was left permanently disabled.
Walsh later applied to the State Comptroller's Office for performance-of-duty disability retirement benefits, which are given to certain public workers injured on the job, as long as the facts of the incident line up with the statute, the Retirement and Social Security Law §607-c(a).
The Comptroller's Office decided that, while Walsh had been injured on the job, the events that led to her injury didn't meet the requirements for her to receive those benefits, the amount of which is higher than ordinary disability benefits.
After Walsh asked the state to reconsider, a hearing officer appeared to blame the incident on her, rather than the inmate who fell on her. Her request was denied again.
"The applicant's mishap is more appropriately attributed to her failure to carefully execute her task of removing an inmate from the van," the hearing officer wrote.
That decision was upheld last year by the Appellate Division, Third Department, which said that what happened to Walsh didn't fit a specific part of the law that would allow her to collect performance-of-duty disability retirement benefits.
That section says the injury must be the result of "any act of any inmate," which isn't defined in the law. The Appellate Division wrote that what happened to Walsh wasn't considered as such.
That's because, in that court's interpretation, "any act of any inmate" was required to be "volitional or disobedient in a manner that proximately causes his or her injury." Because Walsh's injury was caused by an accidental fall, it wasn't covered, the court said.
The Court of Appeals reversed that interpretation in its decision Monday, which largely divulged into different views of the word "act," as in "any act of any inmate."
"We're very happy with the decision," Edelstein said. "I think the majority did the right thing by adopting a broad definition of what an 'act of any inmate' is and declining to impose artificial limitations."
Because the word isn't defined in the law, Feinman looked at how it's been used by the Legislature in the past, and how it's been defined elsewhere. In the state's penal law, for example, an "act" is defined as "a bodily movement," with a separate definition for what's considered an involuntary act.
In previous decisions, the Court of Appeals has also used the word "act" to refer to something involuntary, such as an "act of falling." This case should be no different, Feinman wrote.
"While many ways in which the legislature could have narrowed the term come easily to mind, it is hard to imagine how it could have written the statute more broadly," Feinman wrote.
"Here, the inmate took one to two steps, lost her balance, and landed on petitioner, injuring her. Petitioner's injuries were thus sustained by 'any act of any inmate,' i.e., the inmate's fall on petitioner," he continued.
That view was not shared by Associate Justice Jenny Rivera, who penned a dissent that agreed with the Appellate Division's interpretation of the word "act."
Rivera wrote that the Legislature purposefully separated performance-of-duty disability retirement benefits from ordinary disability benefits for cases where an inmate willfully causes injury to a correction officer or others covered by the law.
In the case of Walsh, Rivera wrote, the inmate accidentally slipped and fell on her. That's different from if an inmate sought to injure her, which would have qualified her for the specialized benefits she sought from the Comptroller's Office.
"Here, because it is undisputed that the inmate accidentally slipped and fell on petitioner, the injuries are not the result of an act of an inmate and so the Comptroller properly denied her request for performance-of-duty benefits," Rivera wrote.
She pointed, in part, to the dictionary definition of the word "act." It's defined in Merriam-Webster as "something done voluntarily," which is not what happened here, Rivera wrote.
She criticized, harshly, the court's four majority justices for coming to the opposite conclusion in their decision.
"Although I conclude that the word 'act' as used in RSSL 607-c (a) may plainly be interpreted to refer solely to volitional conduct, the majority's view that the word unambiguously includes involuntary physical movement is based on a patchwork of secondary sources that are anything but clear," Rivera wrote.
Rivera was jointed on the dissent by DiFiore and Associate Justice Leslie Stein. Feinman was joined on the majority opinion by Associate Justices Eugene Fahey, Michael Garcia, and Rowan Wilson, who also penned a separate opinion.
Representatives from the State Comptroller's Office did not respond to a request for comment Monday.
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