Caulkins v. Town of Pound Ridge

Proceeding pursuant to CPLR article 78 to review a determination of the Town Board of the Town of Pound Ridge dated November 28, 2012, which adopted the findings and recommendations of a hearing officer dated November 12, 2012, made after a hearing, that the petitioner’s current disability is not related to a line-of-duty injury, and terminated the petitioner’s benefits pursuant to General Municipal Law § 207-c.

Judicial review of an administrative determination made after a hearing required by law at which evidence is taken is limited to whether the determination is supported by substantial evidence (see CPLR 7803 [4]; 300 Gramatan Ave. Assoc. v State Div. of Human Rights, 45 NY2d 176 , 181 [1978]). Substantial evidence consists of “such relevant proof as a reasonable mind may accept as adequate to support a conclusion or ultimate fact” (300 Gramatan Ave. Assoc. v State Div. of Human Rights, 45 NY2d at 180 ).

In order to be eligible for disability benefits pursuant to General Municipal Law § 207-c, the petitioner must “prove a direct causal relationship between job duties and the resulting illness or injury” (Matter of White v County of Cortland, 97 NY2d 336 , 340 [2002]; see Matter of Lowther v County of Rockland, 122 AD3d 845 , 846 [2014]; Matter of Tancredi v Town of Harrison/Vil. of Harrison Police Dept., 72 AD3d 832 , 834 [2010]). Here, substantial evidence supports the hearing officer’s determination that the petitioner’s current disability is not causally related to the on-the-job injuries she suffered on October 4, 2008.

Dillon, J.P., Miller, Duffy and LaSalle, JJ., concur.