Overturning disability retirement decisions
Guidal v Trustees of the NYC Fire Department Article 1-B Fund, 275 AD2d 458
The Guidal decision by the Appellate Division demonstrates the difficult test that a claimant faces in attempting to have a court overturn a decision by the trustees of a pension fund denying his or her application for accidental disability retirement benefits.
William Guidal, a New York City firefighter, applied for accidental disability retirement benefits. The Trustees, by a tie vote, disapproved his application for accidental retirement benefits but approved him for ordinary disability retirement benefits.
Guidal’s appeal was rejected by the Appellate Division. The court observed that:
Where the Board of Trustees of the New York City Fire Department, Article 1-B Pension Fund ... denies an application for accidental disability benefits as a consequence of a tie vote, the Board’s determination can be set aside on judicial review only if it can be concluded as a matter of law that the petitioner’s disability was the natural and proximate result of a service-related injury.
The test applied in such cases by the courts: the courts may intervene only where it finds that circumstances allow but one inference with respect to the cause of the disability. In such situations the court may determine the conclusion to be drawn from the inference under the circumstances. In other words, it may decide whether or not the Trustee’s inference and conclusion was correct.
In contrast, where there is a difference of expert medical opinion as to the cause of the disability, the Trustees’ determination must be sustained if supported by substantial evidence.
Accordingly, if there is any credible evidence that the disability was not caused by service-related injuries supporting the Trustee’s determination, that determination must stand.*
In Guidal’s situation, said the court, Guidal failed to establish, as a matter of law, a causal connection between his line-of-duty accidents and his disabling condition since the medical evidence permitted more than one inference to be drawn as to the cause of his disabling condition.
Applying the single inference test, the Appellate Division held that there was no basis to disturb the Trustee’s decision.
* The State Comptroller is the sole trustee of the New York State Employees’ Retirement System. Presumably the same analysis would be applied in cases where his determination concerning approving an application for accidental or duty-related disability benefits is at issue.
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