Uniformed Firefighters Ass'n v. Beekman

420 N.E.2d 938, 52 N.Y.2d 463, 438 N.Y.S.2d 746, 1981 N.Y. LEXIS 2284
CourtNew York Court of Appeals
DecidedApril 2, 1981
StatusPublished
Cited by66 cases

This text of 420 N.E.2d 938 (Uniformed Firefighters Ass'n v. Beekman) is published on Counsel Stack Legal Research, covering New York Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Uniformed Firefighters Ass'n v. Beekman, 420 N.E.2d 938, 52 N.Y.2d 463, 438 N.Y.S.2d 746, 1981 N.Y. LEXIS 2284 (N.Y. 1981).

Opinions

OPINION OF THE COURT

Wachtler, J.

The question in these cases is whether section 207-k of the General Municipal Law, often called the “heart bill”, establishes a presumption that a disabling or fatal heart condition suffered by a New York City policeman or fireman was accidentally sustained as a result of his employment which, if not rebutted by contrary proof, entitles the employee or his family to accidental, line-of-duty pension or death benefits.

The courts below held that the statute establishes such a presumption. The city and its representatives appeal. They concede that the statute establishes a presumption that the heart condition was job related. They urge, however, that it does not create any presumption that the heart condition was accidental. Thus in their view, to qualify for the benefits, the employee or his family must affirmatively prove that the heart condition which caused the disability or death was the result of a particular accident occurring at a specific time and place.

The City of New York has long provided special pension benefits to police officers and firemen who become disabled as a result of their service to the city. Prior to 1940 these line-of-duty retirement benefits were payable upon a -finding that the disability was job related; there was no re[468]*468quirement that it be the result of an accident (L 1920, ch 427, § 1; Administrative Code of the City of New York, §§ B18-4.0, B19-4.0). In that year, however, when the present retirement system was adopted, the Administrative Code sections providing line of duty disability and death benefits for policemen and firemen required and still require proof that the employee’s disability or death was accidental (Administrative Code, §§ B18-39.0, B18-43.0, B19-7.8, B197.84). Thus, for instance, line-of-duty death benefits are not payable unless there is evidence that the employee’s death “was the natural and proximate result of an accident sustained while a member and while in the performance of duty at some definite time and place and that such death was not the result of wilful negligence on his part” (Administrative Code, §§ B18-39.0, B19-7.8).

In most cases, where a police officer or fireman suffers a sudden traumatic injury during a particular incident, the code’s requirement of proof establishing a job-related accident poses no real impediment to recovery of a line-of-duty pension or death benefits. For many years, however, the police and firemen’s associations have urged the Legislature that this requirement creates an unrealistic, if not impossible, burden of proof in cases where death or disability results from a heart condition. It is their position that statistical and medical studies show that heart conditions are an occupational hazard for firemen and police officers serving in large metropolitan areas. They claim that such conditions are the result of a gradual process attributable to the continuous stress and sudden bursts of physical and mental strain routinely required in the line of duty and that it is unrealistic to look for particular incidents as the cause (see, e.g., Memorandum, NY Legis Ann, 1970, pp 85-86). Throughout the years various public officials and agencies have opposed, and continue to oppose, any relaxation of the burden of proof in these cases, noting that heart conditions are generally not considered job-related accidents and that there is insufficient support for the contention that this is a special risk for those employed as firemen or police officers.

From 1948 to 1968 a dozen heart bills similar to section [469]*469207-k of the General Municipal Law were passed by the Legislature but on each occasion were vetoed by the Governor (see State Division of the Budget Report, May 4, 1970, reprinted in the Appendix to Uniform Firefighter’s Assn, v Beekman, at p 191). Finally in 1970, the Legislature passed and the Governor signed section 207-k of the General Municipal Law, which in relevant part provides: “Notwithstanding the provisions of any * * * administrative code to the contrary * * * any condition of impairment of health caused by diseases of the heart, resulting in total or partial disability or death to a paid member of the uniformed force of a paid police department or fire department * * * who successfully passed a physical examination on entry into the service * * * which examination failed to reveal any evidence of such condition, shall be presumptive evidence that it was incurred in the performance and discharge of duty, unless the contrary be proved by competent evidence.”

The statute which was originally effective for a year was reenacted annually until 1979 when it was extended for a two-year period expiring on June 30, 1981 (L 1979, ch 321). Following the adoption of this statute, at least until 1979, the Boards of Trustees of the Police Department Pension Fund and the Fire Department Pension Fund granted accidental line-of-duty disability pensions and death benefits in heart cases without requiring proof that the condition was the result of any particular accidents or incidents in the employee’s career. In 1973 the Corporation Counsel of the City of New York endorsed this action by issuing an opinion in which he concluded that it carried out the evident intent of the Legislature.

In recent years, however, the Mayor of the City of New York has spoken against the heart bill and in 1979 urged the Legislature not to reenact it. In addition the Corporation Counsel informed the board of trustees of the pension fund that “it does not have discretion to interpret” the statute “as it has in the past”. Rejecting the 1973 opinion of his predecessor, the Corporation Counsel issued a new opinion (No. 22-79) in which he concluded that “accidental causation of heart disability or death is not to be presumed under 207-k”; instead the burden is on the applicant to [470]*470prove that the disabling or fatal heart condition was accidentally caused. He also informed the trustees that accidental causation could not be established by proof of a “health impairment which progressively develops from the performance of the duties” normally associated with the position. Rather the applicant must show that the condition was the result of a particular, sudden and unexpected event in which the employee was not performing “the ordinary activities expected of persons in such employment.”

The sponsor of the 1979 reenactment of the statute expressly rejected this interpretation and stated on the record that the purpose of the bill was to create a presumption which “extended to every element of proof of a line of duty disability, including proof of the line of duty accidental nature of the disability * * * [this] presumption would prevail where there was not substantial competent evidence to show that the heart disability was not sustained by a line of duty accident.”

The 1979 opinion of the Corporation Counsel produced a deadlock in each of the boards, which by statute are composed of representatives of the city and the employees, each group having an equal number of votes with 7/12ths necessary for a quorum and to sustain any board action (Administrative Code, §§ B18-13.0, B18-2.0, B19-7.56). The city trustees made clear their intention to deny any heart disability applications which were not supported by evidence of accidental causation as prescribed in the opinion of the Corporation Counsel, thus relegating the applicant to ordinary disability or death benefits (Matter of City of New York v Schoeck, 294 NY 559).

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Bluebook (online)
420 N.E.2d 938, 52 N.Y.2d 463, 438 N.Y.S.2d 746, 1981 N.Y. LEXIS 2284, Counsel Stack Legal Research, https://law.counselstack.com/opinion/uniformed-firefighters-assn-v-beekman-ny-1981.