New York Court of Appeals

Uniformed Firefighters Association, Local 94, Iaff, Afl-Cio, Respondents v. Augustus A. Beekman, as Fire…

April 2, 198152 N.Y.2d 463

Summary

The Court held that section 207‑k of the General Municipal Law creates a rebuttable presumption that a disabling or fatal heart condition suffered by a New York City police officer or fireman was accidentally incurred in the performance of duty, thereby entitling the employee or his family to accidental line‑of‑duty pension or death benefits unless contrary proof is offered. The holding rests on the statute’s legislative history, the consistent administrative interpretation, and the Legislature’s repeated reenactments, which the Court deemed indicative of intent. The Court affirmed the Appellate Division's orders. Justice Jasen dissented, arguing that the statute’s plain language does not support a presumption of accidental causation.