In Matter of G.C. v New York City Employees' Retirement System, the Appellate Division, Second Department reversed a lower court judgment that had annulled a determination by the Board of Trustees denying disability retirement benefits to petitioner G.C. The case involved multiple applications filed by G.C. following two work-related incidents in 2014. He claimed a range of physical impairments, including degenerative conditions and carpal tunnel syndrome, which he argued rendered him unable to perform his job duties.
The Medical Board examined G.C. on several occasions and issued four reports over the course of several years, consistently concluding that he was not disabled. These findings were adopted by the Board of Trustees, resulting in repeated denials of his applications. After an earlier court remanded the matter for a more detailed explanation, the Medical Board issued a fourth report in 2020 that reaffirmed its prior conclusions with greater specificity. The Board of Trustees adopted this report in 2022, prompting G.C. to initiate the present CPLR article 78 proceeding.
The appellate court emphasized that under Retirement and Social Security Law § 605(b)(3), G.C., who had fewer than ten years of service credit, bore the burden of proving that his incapacity was the natural and proximate result of an accident sustained in the performance of duty. The Medical Board’s determination was supported by credible evidence, including medical records showing that G.C.’s hip condition was degenerative and predated the incidents. His continued employment for 18 months after the first incident further undermined the claim of disability. The Medical Board also noted symptom magnification and inconsistencies between its own observations and those of G.C.’s treating physicians. Additionally, his carpal tunnel syndrome was not considered disabling because he declined surgical treatment.
Given the substantial evidence supporting the Medical Board’s findings, the court held that the Board of Trustees’ determination was neither irrational nor arbitrary. It concluded that the Supreme Court erred in annulling the determination and granted judgment in favor of the respondents, dismissing the proceeding on the merits.
Ironically, the system is stiff ....
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DECISION