State Industrial Commissioner v. Leff

Brief Fact Summary.

A printing employee died in an explosion and the State Industrial Board awarded his survivors damages. Owners of the printing shop appealed.

Synopsis of Rule of Law.

Worker’s Compensation Law is written with the primary purpose of providing economic assistance to an employee who is injured on the job and thereby suffers a loss of earnings

Facts.

The Appellants, Herman and Lillian Leff, were engaged in the printing business. They employed the deceased as a press feeder. The injury causing his death resulted from an explosion in an adjoining building which caused the wall of the latter building, which extended up four stories above the roof of the employers’ premises, to fall over onto and through the roof of the printing shop crushing the employee beneath the falling material. Appellants contended that the accident in question was not of the type that would warrant compensation as they were not sustained in connection with claimant’s employment.

Issue.

Were the injuries sustained by decedent sustained in the course of employment and thus entitled to compensation?

Held.

Yes. Affirmed. The New York Supreme Court affirmed the order of the Appellate Division of an award granted by the State Industrial Board made under the Workmen’s Compensation Law.

Discussion.

Courts must examine statutes in order to determine whether the statute was designed to protect against the type of harm suffered by the plaintiff and whether the class of persons designed to be protected by the statute includes the plaintiff – as here, where legislation was passed to promote worker safety.
As one court has explained, “The primary purpose of workmen’s compensation is to provide economic assistance to an employee who is injured and thereby suffers a loss of earnings; such legislation is intended to impose upon the employer the burden of taking care of the casualties occurring in his employment, thus preventing the injured employee from becoming a public charge” See