## Facts

- John R. Langan and Neal Conrad Spicehandler were committed domestic partners from 1986 until Spicehandler’s death in 2002.
- In 2000, while both were New York residents, they entered into a civil union in Vermont.
- In 2002, Spicehandler was injured in a work-related accident while employed in Langan’s insurance business, underwent surgery, and later died.
- The workers’ compensation carrier accepted the injury and death as work-related but disputed whether Langan qualified as Spicehandler’s “surviving spouse” for death benefits under Workers’ Compensation Law (WCL) § 16(1-a).
- A Workers’ Compensation Law Judge found Langan lacked standing to claim death benefits; the Workers’ Compensation Board affirmed.
- Langan appealed to the Appellate Division, Third Department.

## Issues

1. Whether a partner to a Vermont civil union qualifies as the “legal spouse” and thus “surviving spouse” under WCL § 16(1-a).
2. Whether comity requires New York to recognize a Vermont civil union as equivalent to marriage for purposes of WCL § 16(1-a) death benefits.
3. Whether limiting WCL § 16(1-a) death benefits to “legal spouse[s]” violates the Equal Protection Clause when applied to same-sex civil-union partners.

## Decision

- The Appellate Division affirmed the Board’s determination that Langan lacked standing to claim death benefits as a surviving spouse.
- The court held that “legal spouse” in WCL § 16(1-a) does not include a Vermont civil-union partner.
- The court held comity did not require treating a Vermont civil union as marriage for this statutory benefit scheme.
- Applying rational-basis review, the court rejected the Equal Protection challenge.

## Legal Principles

- Where a benefits statute grants priority to a “surviving spouse” defined as the employee’s “legal spouse,” courts apply the statutory text and do not expand spousal status absent legislative action.
- A civil union created under another state’s distinct statutory framework is not necessarily treated as marriage for purposes of a New York benefits statute that uses “legal spouse” as the eligibility trigger.
- Comity is discretionary and does not compel recognition that would alter the operation of a New York statutory classification when the Legislature has not provided for that status.
- Classifications in social-welfare legislation are reviewed under rational-basis scrutiny unless a suspect or quasi-suspect classification is involved; administrative simplicity and reliance on established legal categories may supply a rational basis.

## Conclusion

The court held that a Vermont civil-union partner was not a “legal spouse” under WCL § 16(1-a), and that neither comity nor equal protection required extending workers’ compensation death benefits to civil-union partners absent legislative authorization.


Matter of Langan v. State Farm Fire & Cas., 48 A.D.3d 76, 849 N.Y.S.2d 105 (N.Y. App. Div. 3d Dep’t 2007)