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Court Rules That Workers’ Compensation Principles Should Be Applied to At-Home Workers

In a recent decision from New York State’s Third Department of their Appellate Division, workers’ compensation claims from employees working from home must be decided using the long-standing definitions of what constitutes a “short break” or what is “work-related” or personal. The decision came from the recent case, In the Matter of the Claim of Christopher Capraro, Appellant, versus Matrix Absence Management et al., Respondents. Workers’ Compensation Board, Respondent.

In 2016, the claimant, Christopher Capraro, ordered office furniture to use in a home office for his new job. His employer informed Capraro that the company would not reimburse him for the furniture as they had already provided him with the necessary computer equipment for the role. When the unassembled furniture was delivered in boxes on June 13, 2016, Capraro attempted to haul them into his home. In the process, he injured himself. In 2017, Capraro filed for workers’ compensation benefits, claiming the injury sustained in carrying the boxes of furniture caused him to stop working.

The Workers’ Compensation Law Judge assigned to his claim denied it, finding that his injuries did not arise from a sufficiently work-related activity. Capraro appealed the decision to a panel of the Workers’ Compensation Board, which upheld the Law Judge’s decision, despite one board member’s dissent.

Capraro then appealed to the full Workers’ Compensation Board, which upheld the previous decision. Capraro appealed a third time to the New York Appellate Division, Third Department. In a ruling published by the Appellate Division on Oct. 22, 2020, the appeals division determined that the previous denials for workers’ compensation benefits were based on a new, overly strict set of standards.

Home Residence as a Place of Employment

According to the appeals division’s statement, “a ‘regular pattern of work at home’ renders the employee’s residence ‘a place of employment’ as much as any traditional workplace maintained by the employer.” Therefore, Capraro was injured during his regular work shift at his workplace and should be considered for workers’ compensation based on the traditional set of standards.

As a result, the appeals court remitted the decision back to the Workers’ Compensation Board to assess Capraro’s claim using the long-established standard. In remitting the decision back to the Workers’ Compensation Board, the appeals court recommended that the Board accept that a “short break or some similar ‘momentary deviation from the work routine for a customary and accepted purpose’ does not constitute an interruption in employment sufficient to bar a claim for benefits.” Therefore, Capraro did not sufficiently interrupt his work time when moving the boxes.

Contact a New York Workers’ Compensation Attorney

If you were injured while working from home, you may be wondering whether you are eligible for workers’ compensation benefits. Our attorneys can help you develop a compelling case and secure the maximum compensation you deserve. Call the New York City workers’ compensation attorneys at Hach & Rose, LLP to see how much your case might be worth. Our number is (212) 779-0057.


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