## Facts

- Myles Carroll worked as an ice-wagon driver for Knickerbocker Ice Company, which operated as a self-insurer under New York’s Workmen’s Compensation Law.
- On September 22, 1914, he allegedly suffered a workplace injury while delivering ice when a large block of ice fell on him.
- No witness observed the alleged accident, and there was no independent contemporaneous account confirming it occurred.
- The claimant, Bridget Carroll (the widow), relied primarily on the decedent’s later statements to her and to physicians describing the ice block incident and resulting pain.
- Physicians who examined the decedent reportedly found no objective evidence of injury.
- The decedent later died, and the widow sought death benefits, asserting that death resulted from the alleged work-related accident.

## Issues

1. Whether a workers’ compensation award may be sustained when the occurrence of the alleged workplace accident is proved only by the deceased employee’s uncorroborated hearsay declarations.
2. Whether such uncorroborated declarations are sufficient to establish causal connection between the alleged accident and the employee’s death.

## Decision

- The New York Court of Appeals reversed the compensation award.
- The court held that the decedent’s uncorroborated hearsay statements were insufficient to prove that a compensable accident occurred in the course of employment.
- Because there was no competent proof of the accident and its causal relation to death, the award could not stand.

## Legal Principles

- Although workers’ compensation proceedings are informal and not bound by strict technical rules of evidence, an award must rest on a reliable evidentiary basis establishing essential facts.
- Retrospective, narrative statements describing a past event are hearsay when offered to prove the event occurred; when they are the sole proof of accident and causation, they are insufficient to support an award.
- The claimant bears the burden to prove both (a) the occurrence of an accident arising out of and in the course of employment and (b) causation between the accident and the claimed injury or death.
- Lack of corroboration and absence of objective medical findings may defeat proof of both accident and causation in death-benefit claims.

## Conclusion

The court reversed a workers’ compensation death-benefit award because the record lacked competent evidence of a workplace accident and causation, relying instead on the deceased employee’s uncorroborated hearsay declarations.


Carroll v. Knickerbocker Ice Co., 113 N.E. 507 (N.Y. 1916)