Court Determines Jurisdiction of Respirator Injury Suits Stemming from Rescue After 9/11
New York Law Journal

June 23, 2003

BY TOM PERROTTA

The date New York City called off the search for World Trade Center survivors should determine whether rescue workers suing the city for respiratory injuries bring their claims in state or federal court, a federal judge has ruled.

Southern District Judge Alvin K. Hellerstein ruled that alleged respiratory injuries suffered from Sept. 11 to Sept. 29, 2001, the day the rescue operation officially ended, were closely tied to the attacks and exclusively governed by federal legislation enacted to limit the liability of the city and the Port Authority.

However, the judge said, injuries alleged after Sept. 29 or at a site other than the World Trade Center, such as the Fresh Kills landfill on Staten Island, were sustained in an environment akin to a clean-up operation and should be governed by the standards of New York Labor Law under the jurisdiction of State Supreme Court.

The distinction between state and federal court could figure into the outcome of a lawsuit, because the city's liability for federal claims is limited to $350 million by The Air Transportation Safety and Stabilization Act of 2001 and subsequent amendments. Claims under state jurisdiction are not subject to a cap. Judge Hellerstein's ruling arises out of 35 suits brought by more than 1,200 rescue workers, mostly firefighters, who say that they suffered severe respiratory injuries from breathing toxins at the site, and that the city failed to provide them with proper respiratory masks and protective gear.

The suits were originally filed in State Supreme Court, but the city, relying on the Stabilization Act, removed the suits to the Southern District. Title IV of the act is the Victim Compensation Fund, which authorizes monetary awards for victims' families and injured workers who were at the site within 96 hours of the attack, provided that they forgo their right to file World Trade Center lawsuits.

Plaintiffs in nine of the 35 suits moved to remand their claims to Supreme Court. They argued that the unique conditions of the attack were relevant not to jurisdiction, but to the reasonableness of the city's conduct. The city responded that all claims resulting from the unprecedented attacks should be preempted by the federal legislation. Judge Hellerstein essentially ruled that neither party was interpreting the legislation quite right.

"The heroic efforts by firefighters, police officers and co-workers to rescue people in the buildings, and the frantic search by firefighters, police officers, clean-up workers and volunteers for survivors were expected, natural and foreseeable consequences of the crashes," Judge Hellerstein wrote in In Re World Trade Center Disaster Site Litigation, 02 Civ. 8434. "If, however, death or injury occurred as demolition and clean-up efforts proceeded after September 29, 2001, the causal relationship with the terrorist-related aircraft crashes becomes attenuated, and duties and responsibilities associated with the workplace become predominant.ˆ§

When told of the judge's ruling, Michael A. Barasch of Barasch McGarry Salzman & Penson, who was appointed liaison counsel for the plaintiffs' suits by Judge Hellerstein, said the judge had "split the baby."

"As a practical matter, I can tell you that these lungs didn't know the difference in the air they were breathing from Sept. 11 or Dec. 11," Mr. Barasch said. "But having said that, it makes no difference to me at all. I think the Victim Compensation Fund is the most wonderful thing that's happened to the rescue workers down there."

Rule Change

Though the fund originally excluded rescue workers, Mr. Barasch said that the fund's special master, Kenneth R. Feinberg, had recently changed the rules to compensate those present within 96 hours. So far, Mr. Barasch said, he has received more than a dozen six-figure awards for clients and will be advising clients to accept the fund. He said the awards were significantly higher for claimants who could show economic loss rather than just pain and suffering.

A spokeswoman for the Corporation Counsel's Office, which represented the city, said the city was still reviewing the ruling and could not comment.

Matthew Maiorana, assistant chief of the World Trade Center litigation unit, argued the motion for Corporation Counsel.

(Copyright New York Law Journal, 2003) Reproduced with permission of the copyright owner. Further reproduction or distribution is prohibited without permission.