WITHEY MILES VS. BOARD OF TRUSTEES, POLICE AND FIREMEN'S RETIREMENT SYSTEM(BOARD OF TRUSTESS AND POLICE AND FIREMEN'SRETIREMENT SYSTEM), A-5622-15T1

Background

Miles, a university police officer, injured his left knee in 2007 (kicked by a patient), returned to work, then suffered another knee incident in 2011 (twist and being struck).
He later required a left knee replacement and applied (Sept. 2012) for accidental disability retirement benefits, claiming the 2007 and 2011 incidents caused permanent, total disability.
The Board denied accidental disability benefits, finding his disability resulted from pre-existing degenerative osteoarthritis (aggravated by work) but awarded ordinary disability benefits based on other medical reasons.
At the administrative hearing, Board expert Dr. Rosa and Miles’s expert Dr. Becan agreed the 2011 incident aggravated pre-existing tricompartmental osteoarthritis; neither concluded the trauma was the direct cause of the disability.
The ALJ and the Board found the 2011 incident was not the "essential significant or substantial contributing cause" of the disability and denied accidental disability benefits; Miles appealed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Miles’s disability is a "direct result" of an on-duty traumatic event such that accidental disability benefits apply	Miles: the 2007/2011 incidents aggravated his knee and rendered him permanently and totally disabled	Board: disability stems from pre-existing degenerative osteoarthritis; incidents only aggravated/accelerated it, so benefits are ordinary not accidental	Held: Denial affirmed—medical evidence shows pre-existing osteoarthritis was the direct cause; trauma only aggravated it, so not accidental
Whether the 2011 incident qualifies as an identifiable traumatic event under the statute	Miles: 2011 event was an identifiable, undesigned traumatic event during duty	Board: did not dispute it was traumatic but argued it was not the direct cause of disability	Held: Court accepted it was a traumatic event but ruled it was not the direct cause of disability
Whether Board decision lacked substantial credible evidence or was arbitrary/capricious	Miles: Board misapplied law or ignored evidence showing direct causation by workplace trauma	Board: decision supported by credible expert testimony and consistent with statutory standard and precedent	Held: Board’s factual findings supported by substantial credible evidence; not arbitrary or capricious
Standard of review for agency findings of fact and statutory interpretation	Miles: (implicit) appellate court should reverse	Board: defer to agency factual findings; de novo review of legal issues	Held: Court applied deferential review to facts and de novo review to legal interpretation; affirmed Board

Key Cases Cited

Gerba v. Bd. of Trs., 83 N.J. 174 (explaining that disability from underlying conditions aggravated by trauma is "ordinary" rather than "accidental")
Richardson v. Bd. of Trs., 192 N.J. 189 (setting elements for accidental disability: permanent total disability as direct result of identifiable, undesigned, external traumatic event occurring in performance of duty)
Russo v. Bd. of Trs., 206 N.J. 14 (framework for judicial review of administrative agency action)
In re Application of Virtua-West Jersey Hosp. for a Certificate of Need, 194 N.J. 413 (standard for disturbing administrative determinations)
Lavezzi v. State, 219 N.J. 163 (presumption of validity for agency exercises of delegated responsibilities)
Brady v. Bd. of Review, 152 N.J. 197 (clarifying standard for appellate review of administrative factfinding)