Robert Grone v. Board of Trustees, Etc.
A-1493-23
N.J. Super. Ct. App. Div.May 1, 2025Background
- Robert Grone, a laborer for Maple Shade Township, fell while exiting a front-end loader at work in October 2017, suffering hip and back injuries.
- Following the accident, Grone's condition worsened, and he was ultimately unable to return to work; scans showed a hip tear and back injury.
- Grone applied for Accidental Disability Retirement (ADR) benefits, which the Board of Trustees denied, citing a pre-existing, degenerative condition as the cause of disability.
- Competing medical expert testimony was presented: Grone’s expert attributed disability to the accident, while the Board’s expert identified long-standing degeneration as the cause.
- The Administrative Law Judge (ALJ) credited the Board's expert and found the accident was not the proximate cause of the disability, a decision the Board affirmed; Grone appealed.
- The Appellate Division found the ALJ inconsistently applied the legal standard for causation and remanded for reconsideration under the correct standard.
Issues
| Issue | Grone's Argument | Board's Argument | Held |
|---|---|---|---|
| Proper causation standard for ADR benefits | ALJ used an incorrect, stricter standard | Denial was reasonable and supported by evidence | Remanded: ALJ's causation test was wrong; should use "essential significant cause" |
| Whether accident was substantial cause of injury | Accident was acute, primary cause of disability | Disability due to pre-existing degeneration | Remanded: Must re-evaluate if accident was essential or substantial contributing cause |
| Consideration of pre-existing conditions | No prior disabling hip symptoms before accident | Degenerative disease was pre-existing, not traumatic | Remanded: Board must analyze if accident acted in combination with pre-existing issue |
| Application of agency decision standard | Agency acted arbitrarily, misapplied law | Agency’s fact findings supported, legally sufficient | Remanded: Legal misapplication requires new agency determination |
Key Cases Cited
- Richardson v. Bd. of Trustees, Police & Firemen's Ret. Sys., 192 N.J. 189 (N.J. 2007) (sets multifactor criteria for ADR benefits eligibility)
- Gerba v. Bd. of Trustees of Pub. Emps.' Ret. Sys., 83 N.J. 174 (N.J. 1980) (causation for ADR satisfied if traumatic event is essential or substantial cause)
- In re Herrmann, 192 N.J. 19 (N.J. 2007) (court’s deference to agency decisions)
- In re Taylor, 158 N.J. 644 (N.J. 1999) (standard for agency findings of fact)