Use this button to switch between dark and light mode.

New York: No Recovery for Claimed Lyme Disease Claim

July 28, 2021 (1 min read)

A safety and security officer, who filed a claim seeking to recover workers’ compensation benefits for alleged Lyme disease almost six years after he filed a report with his employer indicating he had suffered two tick bites, failed to establish a causal connection between his alleged condition and the workplace, held an appellate court in New York. Noting that the officer had tested negative for Lyme disease on three separate occasions and observing that the claimant’s own physician acknowledged that it was unlikely that someone with Lyme disease would be asymptomatic for more than five years after the tick bite, the appellate court held there was substantial evidence to support the Board’s denial of the claim. 

Thomas A. Robinson, J.D., the co-Editor-in-Chief and Feature National Columnist for the LexisNexis Workers’ Compensation eNewsletter, is co-author of Larson’s Workers’ Compensation Law (LexisNexis).

LexisNexis Online Subscribers: Citations below link to Lexis Advance. 

See Matter of Decandia v. Pilgrim Psychiatric Ctr., 2021 N.Y. App. Div. LEXIS 4516 (July 15, 2021)

See generally Larson’s Workers’ Compensation Law, § 51.02.

Source: Larson’s Workers’ Compensation Law, the nation’s leading authority on workers’ compensation law

For a more detailed discussion of the case, see

Sign up for the free LexisNexis Workers’ Compensation enewsletter at