A New York appellate court has upheld a decision that allows a carpenter to receive workers' compensation benefits after suffering a heart attack during a work-related task. The ruling affects workers in similar situations who may face challenges in proving their injuries are job-related. This case highlights the importance of timely filing and the burden of proof in workers' compensation claims.
The case, known as Matter of Mulligan v. Moy Construction Corp. (CV-25-0231), was decided on October 8, 2026, by the Appellate Division of the Supreme Court of the State of New York. The court's ruling emphasizes the need for employers and their insurance carriers to adhere to proper procedures when contesting claims. It serves as a reminder of the rights workers have under workers' compensation laws.
Background
The dispute in this case began when Gerard Mulligan, a carpenter, filed a claim for workers' compensation benefits after suffering a heart attack. Mulligan was asked to assist in a task involving a donkey at the residence of his employer's owner. During the effort to contain the donkey, Mulligan experienced severe chest pains and other symptoms. He later sought medical attention, where doctors confirmed he had suffered a heart attack.
The Workers' Compensation Board initially ruled against Mulligan, stating he had not provided sufficient evidence to prove his injury was work-related. However, Mulligan appealed this decision, arguing that the necessary medical records were available and demonstrated a connection between his heart attack and the physical strain he experienced while working.
The Ruling
The appellate court reviewed the case and determined that the Workers' Compensation Board had made the correct decision by ultimately ruling in favor of Mulligan. The court noted that the employer's insurance carrier had failed to file a notice of controversy within the required timeframe, which limited their ability to dispute the claim. The court stated, "the carrier's failure to timely file a notice of controversy requires the Board to determine, without regard to the carrier's proof, whether claimant demonstrated that the injury was work-related."
Furthermore, the court found that Mulligan had provided credible medical evidence linking his heart attack to the exertion he experienced while trying to manage the donkey. The court quoted from the case, stating, "there was sufficient, unrebutted and credible medical evidence to support a finding of a causal relationship." This ruling reinforced the importance of medical testimony in establishing a connection between work activities and injuries.
Impact
This ruling has significant implications for workers' rights in New York. It underscores the importance of timely filing by employers and their insurance carriers when disputing claims. Workers who suffer injuries while performing their job duties may find it easier to secure benefits if they can provide credible evidence of a causal connection between their work and their injuries.
The decision also serves as a reminder for workers to be aware of their rights under workers' compensation laws. It highlights the need for proper documentation and medical records to support claims, especially in cases involving serious injuries like heart attacks. The ruling may encourage more workers to pursue claims, knowing that the courts will consider their circumstances carefully.
What's Next
The case may still be subject to further appeals, but details were not available in the court filing. There are no related cases pending that are directly connected to this ruling.