DECEDENT’S WORK-RELATED COVID DEATH ENTITLED DECEDENT’S DAUGHTER, DECEDENT’S “STATUTORY BENEFICIARY,” TO “ACCIDENTAL DEATH BENEFITS” UNDER A RECENT STATUTE; PETITIONER, DECEDENT’S PARTNER, WHO WAS DECEDENT’S “DESIGNATED BENEFICIARY” FOR “ORDINARY DEATH BENEFITS,” WAS NOT ENTITLED TO THE “ACCIDENTAL DEATH BENEFITS” (CT APP).
The Court of Appeals, affirming the Appellate Division, determined the respondent Teachers’ Retirement System properly awarded “accidental death benefits” to decedent’s daughter under a recent law which classified certain work-related COVID death as “accidental.” The dispute here was between the “statutory beneficiary,” decedent’s daughter who received the “accidental death benefits,” and the “designated beneficiary,” decedent’s partner, who was entitled to any “ordinary death benefits:”
he statutory text refutes petitioner’s argument that respondent’s denial of her claim for ordinary death benefits was irrational. Retirement and Social Security Law § 607-i (a) (3) provides that the accidental death benefit “shall” be paid to a member’s statutory beneficiary if the member meets the stated criteria. This is consistent with the recognition in the legislative history that “[o]nce the statutory beneficiary demonstrates this proof, entitlement to the [a]ccidental [d]eath [b]enefit is mandatory” … . Additionally, preexisting law provided that an ordinary death benefit is only available when accidental death benefits are unavailable (see Retirement and Social Security Law § 606-a [a] [3]). Matter of Colon v Teachers’ Retirement Sys. of the City of N.Y., 2024 NY Slip Op 01331, CtApp 3-14-24
Practice Point: Here decedent’s daughter was the “statutory beneficiary” of “accidental death benefits” under the Retirement and Social Security Law, and decedent’s partner was the “designated beneficiary” for “ordinary death benefits” under the Retirement and Social Security Law. Decedent’s daughter was properly awarded the “accidental death benefits” under a recent statute covering work-related COVID deaths.