## Facts

- Edward Sullivan, a painter, sustained two compensable workplace injuries to his right knee: one in March 1948 while employed by B. & A. Construction, Inc., and another in June 1949 while employed by A. L. Turner.
- After the work injuries, Sullivan’s knee developed a recurrent tendency to “lock,” temporarily depriving him of use and control of his right leg until it could be “shaken” back into place.
- The locking occurred frequently with pressure on the knee, including during ordinary walking and while braking when driving; Sullivan testified it happened “once or twice a week” when applying the brake pedal.
- On June 30, 1950, while driving in Maryland on a personal trip, Sullivan experienced a steering malfunction later attributed to a broken tie rod.
- As he attempted to brake in response to the emergency, Sullivan’s knee locked and he was unable to apply the brake, resulting in a crash and additional injuries.
- The Workmen’s Compensation Board awarded benefits for the automobile-accident injuries as consequential to the earlier compensable knee injuries; the Appellate Division affirmed.

## Issues

1. Whether injuries sustained in an off-duty automobile accident are compensable as consequential injuries when the claimant’s inability to brake is attributed to a prior compensable knee condition.
2. Whether an intervening mechanical failure in the vehicle severs the causal chain between the compensable knee injuries and the later accident injuries.
3. Whether the claimant’s continued driving despite knowledge of knee locking constitutes an intervening cause that defeats compensability.

## Decision

- The Court of Appeals of New York affirmed the award.
- The court held that substantial evidence supported the Board’s finding that the 1950 automobile-accident injuries were causally related to, and flowed from, the prior compensable knee injuries.
- The court declined to treat the vehicle’s mechanical failure or Sullivan’s decision to continue driving as breaking the causal chain as a matter of law.
- The court emphasized that causation and the weight of competing explanations were for the Board when supported by substantial evidence.

## Legal Principles

- A later injury occurring away from work may be compensable if it is a direct, natural, and proximate consequence of an earlier compensable injury.
- The compensable condition need not be the sole cause of the later injury; it is sufficient if it remains a substantial proximate contributing factor.
- An intervening event does not sever compensability where the original compensable condition actively contributes to the later harm and the Board reasonably finds causal connection.
- Ordinary negligence or arguably imprudent conduct by a claimant does not bar compensation for consequential injuries unless it constitutes a new, independent cause.
- Appellate courts defer to the Board’s causation findings when supported by substantial evidence and do not reweigh credibility or competing inferences.

## Conclusion

The court upheld an award for injuries from an off-duty car crash because the Board could reasonably find, on substantial evidence, that the claimant’s work-related knee condition substantially contributed to the accident and that neither a mechanical malfunction nor the claimant’s continued driving legally severed causation.


Matter of Sullivan v. B. & A. Constr., Inc., 307 N.Y. 161, 120 N.E.2d 694 (N.Y. 1954)