Whether a determination by the Workers' Compensation Board that Plaintiff's injury is work related entitles the injured Plaintiff to General Municipal Law § 207-c benefits by the doctrine of collateral estoppel.

No. The Workers' Compensation Board's determination of the injury-in-performance-of-duty issue does not share an identity of issue with a municipality's decision on a General Municipal Law § 207-c application. The two statutory systems do not examine the same issue and are discrete and independent compensation systems.

Plaintiff, a corrections officer, suffered injuries in an automobile accident, after leaving work on a special duty midnight shift at his place of work, the Nassau County Correctional Center. He filed an "injury sustained while on duty form" requesting General Municipal Law § 207-c benefits, which the County never paid. The County later notified him of its functional denial of the benefits in a letter. Meanwhile, Plaintiff applied for Workers' Compensation benefits, which the Workers' Compensation Board granted, despite the County's opposition. Plaintiff filed a C.P.L.R. Article 78 petition and pressed his § 207-c claim against Defendant. Initially, the Supreme Court dismissed the claim because Defendant had not conducted a medical examination and had indicated that it was going to appeal the Workers' Compensation award.

After Defendant failed to appeal, the Supreme Court granted Plaintiff's petition. The Supreme Court provided two reasons for its decision. First, collateral estoppel prevented Defendant from denying the § 207-c benefits. Second, Defendant failed to show any rational basis for its denial. The Appellate Division affirmed addressing the collateral estoppel issue only. The Court of Appeals granted Defendant's motion to appeal.

The Court found that collateral estoppel does not apply in this case because there is no identity of issue between the Workers' Compensation Law and the General Municipal Law §207-c. The Court rejected Plaintiff's argument that the standards determining entitlement to benefits under both statutes are interchangeable. Instead, the Court found that the two regulatory schemes do not necessarily look at or determine the same issues, in the same manner, or under the same processes and procedures. The statutes, on plain reading, have different phrasing, different legislative histories, and different operational features.

General Municipal Law § 207-c has the narrow goal of compensating specified municipal employees for injuries sustained in the performance of specified work that entails heightened risks. The Court further clarified that the statute is intended to apply to those engaged in the criminal justice process. The Workers Compensation Law is a general and comprehensive program that provides all injured employees with some compensation regardless of fault for ordinary and unqualified employment duties. Furthermore, the Court also cited Workers' Compensation Law § 30 which indirectly recognizes that § 207-c benefits do not automatically vest following a Workers' Compensation award. If the Legislature had intended to create a presumption that a § 207-c award would automatically be granted following a Workers' Compensation award, the Court reasoned the Legislature would have done so explicitly.

The Court also emphasized that the manner and the forum of resolution differ between the two systems. The Independent Workers' Compensation Board determines workers compensation benefits while a municipality itself decides the benefits due under General Municipal Law § 207-c.

Since the Court only determined the collateral estoppel issue, it remitted to the Appellate Division determination of whether the Supreme Court erred in finding that Defendant did not have a rational basis for its decision denying General Municipal Law § 207-c benefits.