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 for his new job to use in a home office. 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. He claimed the injury sustained in carrying the furniture boxes 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 Workers' Compensation Board panel. Which upheld the Law Judge’s decision, despite one board member’s dissent. He 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.
Court Rules That Workers’ Compensation Principles Should Be Applied to At-Home Workers