Extraordinary Workplace Exposure and the “Prevalence” Framework: COVID‑19 as a Compensable Accidental Injury in New York Workers’ Compensation Law

I. Introduction

In Matter of Aungst v. Family Dollar, 2025 NY Slip Op 06530 (Nov. 24, 2025), the New York Court of Appeals addressed a central question that has hovered over workers’ compensation practice since the onset of the COVID‑19 pandemic: under what circumstances is a COVID‑19 infection a compensable “accidental injury” arising out of and in the course of employment?

The case concerns a store manager at a high‑volume “essential” retail store who contracted COVID‑19 in April 2020 and suffered a stroke approximately one week later. The Workers’ Compensation Board awarded benefits, relying on a framework it developed for pandemic cases that looks to the “prevalence” of COVID‑19 in the workplace and the nature of the claimant’s job‑related exposure. The employer challenged that framework as inconsistent with the New York Workers’ Compensation Law, arguing that a claimant must identify a specific workplace exposure, pinpointed in time and space, that caused the infection.

Judge Singas, writing for a unanimous Court, firmly rejected that argument. The Court:

• Upheld the Board’s “prevalence” framework as consistent with the statutory requirement of an “accidental injury,” and
• Found that substantial evidence supported the Board’s determination both that the claimant’s COVID‑19 infection was work‑related and that his stroke was a compensable consequential injury.

This decision cements a significant doctrinal development: infectious disease contracted in the workplace can qualify as an “accidental injury” without proof of a single, pinpointable exposure event, so long as the claimant demonstrates extraordinary workplace exposure using evidence of prevalence and job‑related contact.

II. Factual and Procedural Background

A. Claimant’s Work and Exposure

In early April 2020—just weeks into the first wave of the COVID‑19 pandemic—Frank Aungst was employed as a store manager for Family Dollar. The store was characterized as “high‑volume,” and his role was deemed essential, exempt from state emergency restrictions on public gatherings and many commercial activities.

Key facts about his work and exposure:

• He worked full time, 50+ hours per week during March and April 2020.
• His job required near‑constant contact with the public, either on the sales floor or operating a register.
• The store was frequented by many customers, a significant number of whom did not wear face masks despite an employer policy requiring masking and social distancing.
• Store management instructed employees not to enforce masking and distancing rules.
• Employer did not provide sneeze guards or face masks to employees until mid‑April 2020, i.e., after a significant period of unprotected exposure.

B. Infection and Medical Consequences

On April 23, 2020, Aungst tested positive for COVID‑19. On May 1, he suffered a stroke and was hospitalized for approximately four months, continuing to test positive for COVID‑19 after admission.

His vascular neurologist opined:

• There was a causal connection between the COVID‑19 infection and the subsequent stroke.
• Aungst did not present typical stroke risk factors.
• The stroke exhibited a “classic pattern” consistent with COVID‑19‑related stroke, which occurs in a subset (up to about five percent) of COVID‑19 patients.

C. Limited Non‑Work Exposure

The evidence also showed that, during the incubation period:

• Aungst lived alone.
• He drove alone to and from work; he did not use public transportation.
• He had not traveled, visited family, or socialized with friends in the weeks preceding his positive test.
• His only other meaningful public contact was twice‑weekly medical appointments at a clinic that observed strict COVID‑19 protocols, including masking and social distancing.

This created a stark contrast between his substantial, largely unprotected workplace exposure and his minimal, precaution‑compliant non‑work exposure.

D. Proceedings Before the Board and the Courts

Aungst filed a claim for workers’ compensation benefits alleging:

• He contracted COVID‑19 due to workplace exposure, and
• His stroke was a direct and consequential result of that infection.

The employer controverted the claim. A Workers’ Compensation Law Judge (WCLJ) established the claim, initially characterizing it as an occupational disease with a consequential stroke. On administrative review, the Workers’ Compensation Board:

• Modified the characterization of the COVID‑19 infection from “occupational disease” to an “accidental injury,” and
• Otherwise affirmed the establishment of the claim, including the consequential stroke.

In doing so, the Board explicitly relied on its COVID‑19 “prevalence” framework, consistent with guidance it had published in June 2020 (COVID‑19 & Workers’ Compensation Q & A). It concluded that the nature of Aungst’s work—the high‑volume public contact in an area with rapid COVID spread—created “significantly elevated hazards of environmental exposure” and that the infection thus constituted a work‑related accident within the meaning of Workers’ Compensation Law § 2(7).

The Appellate Division, Third Department, affirmed the Board’s decision (221 AD3d 1222 [3d Dept 2023]). The employer obtained leave to appeal to the Court of Appeals (41 NY3d 908 [2024]). The Court of Appeals now affirms.

III. Summary of the Court of Appeals’ Opinion

The Court of Appeals resolves two main legal questions:

1. Is the Workers’ Compensation Board’s “prevalence” framework compatible with the Workers’ Compensation Law’s definition of a compensable “accidental injury”?
   Holding: Yes. The prevalence framework is consistent with the statute and with the Court’s modern jurisprudence on “accidental injury” caused by disease or environmental exposure, particularly Matter of Middleton and Matter of Johannesen.
2. Is the Board’s decision in this particular case supported by substantial evidence?
   Holding: Yes. The Board rationally concluded, based on the record, that:
   • Aungst’s COVID‑19 infection was an accidental injury arising out of and in the course of employment, and
   • His stroke was a compensable consequential injury causally related to COVID‑19.

In doing so, the Court:

• Rejects the employer’s reliance on the old case Matter of Lerner v Rump Bros to insist upon a single, pinpointable exposure event.
• Reaffirms that an accident in the workers’ compensation context is defined from the “common‑sense viewpoint of the average person.”
• Confirms that prolonged or repeated extraordinary exposure to a harmful condition (including germs) can constitute an “accident,” even if the exact exposure moment cannot be identified.
• Clarifies that proof of causation may rest on inferences from workplace conditions and relative exposure levels, not solely on identification of a specific infected individual.

IV. Precedents and Doctrinal Lineage

A. Matter of Lerner v Rump Bros (1925) and the “Time‑Definite” Accident

The employer’s argument hinges on Matter of Lerner v Rump Bros, 241 NY 153 (1925), which interpreted a predecessor to the current Workers’ Compensation Law. In Lerner, the Court held that a disease developed during employment was compensable only where:

• “the inception of the disease [is] assignable to a determinate or single act, identified in space or time,” and
• the act is “assignable to something catastrophic or extraordinary.”

The employer reads Lerner to mean that a claimant with COVID‑19 must pinpoint a specific workplace exposure—a precise time, place, or encounter with a particular infected person—to satisfy the “accident” requirement.

However, as the Court explains, this strict “time‑definite” approach has been substantially relaxed and reinterpreted in later decisions. Aungst is framed largely as a reaffirmation of that evolution, rather than as a departure from tradition.

B. Matter of Masse v Robinson Co. (1950): The “Common‑Sense Viewpoint”

In Matter of Masse v Robinson Co., 301 NY 34 (1950), the Court moved away from a rigid temporal definition of “accident.” It held that:

• An injury need not be precisely “identified in space or time” or tied to a single catastrophic event to be compensable.
• Instead, whether an event is an “accident” is judged “not by any legal definition, but by the common‑sense viewpoint of the average [person].”

This “common‑sense viewpoint” has become a cornerstone of New York workers’ compensation jurisprudence. Aungst explicitly relies on Masse to underscore that the formalistic “single act at a precise moment” requirement has long since been repudiated.

C. Matter of Middleton v Coxsackie Correctional Facility (1975): Infectious Disease as an Accident

Matter of Middleton v Coxsackie Correctional Facility, 38 NY2d 130 (1975), is a key bridge between occupational accident cases and infectious disease. In Middleton:

• A correction officer contracted tuberculosis (TB).
• He had prolonged, close‑range exposure—two to three hours a day, for three to four months—to an inmate with active TB who persistently coughed at close proximity.

The Court held that:

• The “time‑definiteness” requirement could be satisfied either by the cause or the result of an accident.
• An accident may consist of exposure over a protracted period to a harmful condition culminating in a sudden onset of disease (e.g., collapse, diagnosis).
• It is “not decisive” that the claimant cannot pinpoint the exact date of the injurious exposure.
• The repeated traumatic exposure to the inmate’s coughing was “extraordinary in nature” and thus an “accident” under the statute.

Critically, the Court in Middleton recognized “numerous awards based on diseases, including those caused by germs” as accidental injuries, thereby undermining any notion that infectious diseases are per se occupational diseases or non‑compensable.

D. Matter of McDonough v Whitney Point Cent. School (1961): Classroom Mumps

In Matter of McDonough v Whitney Point Cent. School, 15 AD2d 191 (1961), cited approvingly in Middleton, the Appellate Division upheld an award to a teacher who contracted mumps.

The evidence showed:

• The teacher had “close contact with pupils in her classroom,”
• Eight or ten of those pupils contracted mumps, and
• She was exposed to “an unusual amount of germs” while teaching.

This case supports the proposition that:

• Exposure to an unusual concentration of infection in the workplace (even without proof of which specific child infected the teacher) can constitute an accidental injury.

Aungst uses McDonough to illustrate that proof of causation in infectious disease cases can come from patterns of prevalence and unusual exposure, not only from a single, identified source.

E. Matter of Johannesen v New York City Dept. of Hous. Preserv. & Dev. (1994): Extraordinary Environmental Conditions

Matter of Johannesen, 84 NY2d 129 (1994), involved a claimant whose bronchial asthma was aggravated by cigarette smoke and dust in an unventilated office. The Court held:

• A claimant must show “unusual environmental conditions or events assignable to something extraordinary that caused an accidental injury.”
• Although cigarette smoke might be “relatively endemic” in workplaces, the claimant’s particular exposure was “extraordinary” because of its “exacerbative and excessive quality.”
• Her forced exposure in an unventilated, smoke‑filled office satisfied the definition of an “accident.”

Johannesen is especially important in Aungst because it:

• Confirms that “extraordinary” exposure can be established by showing a significantly heightened level of environmental hazard, even when the hazard (cigarette smoke, germs) is common in society.
• Closely parallels the Board’s “prevalence” concept: both focus on qualitatively and quantitatively heightened exposure compared to ordinary life.

F. Substantial Evidence and Medical Causation Cases

The Court also grounds its review in a familiar line of cases about substantial evidence and expert medical proof, including:

• Matter of Gates v McBride Transp., 60 NY2d 670 (1983): the Board’s decision is upheld if supported by substantial evidence.
• 300 Gramatan Ave. Assoc. v State Div. of Human Rights, 45 NY2d 176 (1978): substantial evidence is “less than a preponderance”; the question is whether the inference is “reasonable and plausible.”
• Matter of Haug v State Univ. of N.Y. at Potsdam, 32 NY3d 1044 (2018): substantial evidence is a “minimal standard” and primarily a rationality review.
• Matter of Pell v Board of Educ., 34 NY2d 222 (1974): clarifies that rationality is central to substantial evidence review.
• Matter of Palermo v Gallucci & Sons, 5 NY2d 529 (1959): expert medical opinion must not be mere “surmise,” but causation need not be proven with scientific certainty; the Board chooses among conflicting experts.
• Matter of Ernest v Boggs Lake Estates, 12 NY2d 414 (1963): a medical opinion of causal relationship need not be expressed in terms of “infallibility or scientifically determined certainty.”

These cases collectively support the Court’s deferential stance toward the Board’s fact‑finding and weighing of medical evidence in Aungst.

V. The Court’s Legal Reasoning in Matter of Aungst

A. Compatibility of the “Prevalence” Framework with Workers’ Compensation Law

The core legal dispute concerns whether the Board’s “prevalence” framework is compatible with:

• Workers’ Compensation Law § 10(1), which grants compensation for injuries “arising out of and in the course of the employment,” and
• Workers’ Compensation Law § 2(7), which defines “injury” as “only accidental injuries arising out of and in the course of employment and such disease or infection as may naturally and unavoidably result therefrom.”

The Board defined “prevalence” as:

“evidence of significantly elevated hazards of environmental exposure that are endemic to or in a workplace which demonstrates that the level of exposure is extraordinary. A claimant may demonstrate prevalence through evidence of the nature and extent of work activities, which must include significant contact with the public and/or co‑workers in an area where COVID‑19 is prevalent.”

The Court holds that this approach:

• Is consistent with the statutory requirement of an “accidental injury,” and
• Faithfully reflects the “extraordinary exposure” requirement articulated in Middleton and Johannesen.

In other words, the prevalence framework is not a new legal test; it is a tailored application of the existing “extraordinary environmental conditions” and “unusual amount of germs” concepts to the COVID‑19 context.

B. Defining “Accidental Injury” in the Context of Infectious Disease

The Court distills its prior case law into a clear rule for infections and environmental exposure:

• To establish that an illness caused by exposure to pathogens or adverse environmental conditions is compensable, the claimant must demonstrate that the illness was caused by “extraordinary” workplace exposure.
• “Extraordinary” means exposure significantly above the risks encountered in everyday life, judged from a common‑sense perspective.

Under this standard:

• COVID‑19 infection contracted in a workplace with intense, frequent public interaction in an area of high community spread can be an “accident.”
• The claimant’s inability to identify the specific moment or source of infection does not defeat the claim.

The Board’s prevalence framework operationalizes this rule by focusing on:

• The nature and frequency of work‑related contact with others (public and co‑workers), and
• The level of COVID‑19 spread in the community where the workplace is located.

C. Causation Without a Single Identifiable Exposure Event

The employer argued that—based on Lerner—a claimant must identify a specific workplace exposure as the cause of infection. The Court rejects that, explaining:

• Modern case law does not confine compensable accidents to injuries “identified in space or time” or “catastrophic or extraordinary” in a narrow sense.
• In Middleton, prolonged TB exposure from one inmate was enough.
• In McDonough, exposure to an “unusual amount of germs” in a classroom (from multiple infected students) was enough.
• In Johannesen, breathing polluted air in a smoke‑filled office was enough, even though the hazard was ubiquitous in society.

The Court makes a critical conceptual point: the difference between:

• Exposure to a single infected individual (as in Middleton),
• Exposure to a group of infected individuals (as in McDonough), and
• Exposure to many members of the public, a substantial proportion of whom are infected (as in a COVID‑19 prevalence scenario)

is fundamentally a difference in the degree and pattern of proof, not in the governing legal standard.

Thus:

• The law does not require identification of a specific person or encounter as the source.
• It requires credible evidence showing that the claimant’s disease “resulted from extraordinary work-related exposure, as opposed to some other source.”
• Allocation of weight among competing causal inferences is for the Board, subject to minimal substantial evidence review.

D. Application of the Substantial Evidence Standard

Having upheld the prevalence framework as lawful, the Court then asks whether the Board’s application of it to Aungst’s case is supported by substantial evidence.

Key features of this standard, as emphasized by the Court:

• It is a “minimal standard.”
• It is “less than a preponderance of the evidence.”
• It requires only that the Board’s inference be “reasonable and plausible,” not necessarily the most probable interpretation of the evidence.
• Judicial review focuses on “rationality.”
• Where expert medical opinions conflict, choosing which to credit is “entirely within the province of the Board.”

Applying this framework, the Court finds substantial evidence for two determinations:

1. COVID‑19 as a work‑related accidental injury.
   The Board had a rational basis to find that:
   • COVID‑19 was rapidly spreading in the local area when Aungst worked there.
   • His position involved “constant” close contact with customers, many unmasked.
   • Employer discouraged enforcement of masking and distancing rules.
   • PPE (masks, sneeze guards) were not provided until mid‑April.
   • COVID‑19 is a highly communicable respiratory illness spread by in‑person contact.
   Given these conditions, the Board could reasonably conclude that Aungst’s job entailed a “significantly elevated” risk of infection—an extraordinary workplace exposure.
2. Work‑relatedness of the infection (causation).
   The Board also had a rational basis to infer that:
   • Outside of work, Aungst’s exposure was minimal (lived alone, no public transit, limited shopping, no social visits, only carefully controlled medical appointments).
   • By contrast, his workplace exposure was intense and largely unprotected.
   From this disparity, it was “reasonable and plausible” to conclude that he contracted COVID‑19 at work rather than through community or domestic exposure.

E. Consequential Injury: Stroke Following COVID‑19

The Court also upholds the finding that Aungst’s stroke was a “consequential injury,” i.e., an additional injury that naturally flowed from the primary compensable injury (COVID‑19 infection).

The Board relied on the testimony of Aungst’s treating neurologist, who:

• Linked the stroke to the COVID‑19 infection.
• Noted the absence of typical, independent stroke risk factors.
• Explained that COVID‑19 increases the risk of blood clots and stroke, including in a noticeable minority of patients.
• Testified that the type and timing of the stroke were “consistent with a COVID‑19‑related stroke.”
• Ruled out other potential causes.

Although the employer offered a contrary expert, the Court underscores that:

• The Board may choose among conflicting expert opinions.
• So long as the credited opinion is grounded in facts and not mere speculation, it constitutes substantial evidence.
• Medical causation need not be proven with “scientific certainty” or in terms of “infallibility.”

On this record, the neurologist’s testimony provided a rational basis for the Board’s finding that the stroke was causally related to the work‑related COVID‑19 infection and thus compensable as a consequential injury.

VI. Complex Concepts Simplified

A. “Arising Out Of” vs. “In the Course Of” Employment

Workers’ Compensation Law § 10(1) compensates injuries that:

• “Arise out of” employment: There must be a causal connection between the work and the injury. The job must create or significantly contribute to the risk that produced the injury.
• “Occur in the course of” employment: The injury must happen during working time, at a place the employee may reasonably be, while engaged in work‑related activities (or activities incidental to employment).

In Aungst:

• “In the course of” is relatively straightforward: the exposure occurred while he was performing his job in the store.
• “Arising out of” is the contested issue: did his work materially increase the risk of infection as compared to ordinary life? The Court answers yes, based on extraordinary workplace exposure.

B. Accidental Injury vs. Occupational Disease

The Workers’ Compensation Law distinguishes between:

• Accidental injuries: Unexpected or unusual events or exposures (even if unfolding over time) that cause injury—such as a fall, a sudden collapse, or extraordinary exposure to a harmful environment or pathogen.
• Occupational diseases: Illnesses that are characteristic of and peculiar to a particular trade, occupation, or process (e.g., asbestosis for asbestos workers, silicosis for miners).

In this case:

• The WCLJ initially classified COVID‑19 as an occupational disease; the Board reclassified it as an accidental injury.
• The Court does not extensively analyze this distinction, but by affirming the Board, it implicitly accepts the idea that:
  • For a retail worker, COVID‑19 contracted during a pandemic is not a disease “peculiar to” retail work; rather, it is an injury arising from extraordinary accidental exposure to a widely circulating pathogen.

Practically, this means many pandemic‑related claims may proceed as “accidental injury” claims, especially where the job involves unusual intensity or concentration of exposure.

C. “Extraordinary” or “Significantly Elevated” Risk

The Court uses terms like “extraordinary,” “significantly elevated,” “exacerbative and excessive,” and “unusual environmental conditions” to describe the level of risk required for a compensable accidental injury based on exposure.

In simplified terms, this means:

• The workplace must expose the employee to hazards at levels meaningfully higher than those faced by the general public in everyday life.
• The exposure should be qualitatively or quantitatively different—for example, closer contact, higher density, longer duration, or absence of protective measures.

For COVID‑19, relevant factors may include:

• Type of job (e.g., frontline retail vs. remote work).
• Frequency and duration of close, face‑to‑face interactions.
• Availability and enforcement of protective measures (masks, barriers, ventilation, distancing).
• Local infection rates at the time (community prevalence).

D. The “Prevalence” Concept in Practical Terms

The Board’s “prevalence” framework, as affirmed in Aungst, essentially asks:

1. How intense was the claimant’s workplace exposure?
   Did the claimant have significant, repeated, close‑range contact with the public or with co‑workers during a period when COVID‑19 was circulating?
2. How prevalent was COVID‑19 in the area and population the claimant interacted with?
   Was the claimant working in a time and place of high infection rates, such that many of the people encountered were likely infected?
3. Did the job place the claimant at a materially higher risk than ordinary life?
   Is there a strong contrast between the level of risk on the job and the claimant’s risk off the job?

If these questions are answered in the claimant’s favor, the Board may find that the claimant experienced “extraordinary” workplace exposure sufficient to treat the resulting infection as an accidental injury.

E. The “Substantial Evidence” Standard Simplified

“Substantial evidence” is the standard courts use to decide whether to uphold administrative decisions like those of the Workers’ Compensation Board. In simplified terms:

• It is not a re‑trial; courts do not decide the case from scratch.
• The question is not “Who is more likely right?”
• The question is: “Is there enough credible evidence that a reasonable person could reach the Board’s conclusion?”
• Even if the court might have decided differently, it must uphold the decision if it is reasonably supported by the record.

In Aungst, the Court emphasizes that this is a “minimal” standard and that rationality—not perfection or certainty—is the touchstone.

VII. Likely Impact of the Decision

A. On Pending and Future COVID‑19 Workers’ Compensation Claims

Aungst provides authoritative guidance for COVID‑19 claims in New York:

• It expressly validates the Board’s existing COVID‑19 guidance and prevalence framework.
• It confirms that:
  • COVID‑19 infections can be compensable accidental injuries.
  • Claimants need not identify a specific exposure event.
  • Claims may succeed where the evidence shows extraordinary workplace exposure, combined with limited or controlled non‑work exposure.

This decision will likely:

• Encourage consistent Board decisions across similar COVID‑19 fact patterns (especially for frontline and essential workers with intensive public contact).
• Reduce litigation focused on the narrow, outdated reading of Lerner requiring a single, pinpointable exposure event.
• Shift the focus of disputes to:
  • Whether a claimant’s workplace exposure was truly “extraordinary,” and
  • Whether competing causal explanations (community spread, household exposure) credibly outweigh the workplace inference.

B. Beyond COVID‑19: Other Infectious and Environmental Exposures

Although the case is framed around COVID‑19, the principles it reiterates are not disease‑specific. They are equally applicable to:

• Other airborne infectious diseases (e.g., influenza, emerging respiratory viruses).
• Diseases spread through close, crowded contact (e.g., certain gastrointestinal or pediatric infections in schools or care facilities).
• Non‑biological environmental exposures (e.g., smoke, dust, chemical fumes) where the claimant’s workplace conditions are unusually intense or unmitigated.

The decision reinforces that:

• Risk becomes “extraordinary” when workplace conditions create a substantially higher exposure than ordinary life, not merely because the hazard exists in the world at large.

C. Guidance for Employers and Insurers

Employer and carrier strategies may need to adjust in light of Aungst:

• Prevention and documentation:
  • Demonstrating robust workplace infection‑control measures (PPE, enforcement of masking/distancing, ventilation improvements) will be central to contesting the “extraordinary exposure” element.
  • Where measures are absent, minimal, or not enforced, employers face a higher risk of findings of extraordinary exposure.
• Defending causation:
  • Merely pointing to community spread is insufficient; carriers will need credible alternate causal narratives (e.g., documented household exposures, high‑risk behaviors outside work).
  • Expert medical testimony must be grounded in the specific claimant’s history, not general skepticism about COVID‑19 causation.

Insurers may also:

• Reevaluate reserves and underwriting for sectors with high public contact (retail, health care, public transportation) during epidemic periods.

D. Guidance for Claimants and Practitioners

For claimants and their attorneys, Aungst suggests several practical points:

• Emphasize job‑related exposure intensity:
  • Quantify hours worked, the density of public interaction, proximity to others, and lack or late arrival of protective measures.
• Document limited non‑work exposure:
  • Evidence that the claimant lived alone, minimized travel, or observed strict precautions outside work can be decisive.
• Use credible medical support:
  • Obtain treating or specialist opinions on both infection‑source likelihood (given job duties) and medical causation (e.g., from COVID‑19 to complications like stroke).

The decision provides a roadmap: show both extraordinary workplace exposure and a credible work‑related causal pathway, rather than attempting to reconstruct a specific exposure event.

E. Administrative Law and Deference to the Workers’ Compensation Board

Aungst is also a robust affirmation of the Board’s interpretive and fact‑finding role:

• The Court defers to the Board’s choice to conceptualize COVID‑19 cases through the “prevalence” lens, as long as that lens fits within existing statutory and case law boundaries.
• The Court reiterates a strong version of substantial evidence review, emphasizing rationality and minimal judicial intervention in weighing evidence and expert opinions.

This signals that:

• Future challenges to the Board’s application of the prevalence framework are unlikely to succeed at the Court of Appeals level unless the Board strays markedly from the “extraordinary exposure” requirement or ignores critical facts.

VIII. Key Takeaways and Conclusion

Matter of Aungst v. Family Dollar is a significant decision in New York workers’ compensation law, particularly for infectious disease claims. Its key takeaways include:

• Validation of the “Prevalence” Framework: The Court explicitly endorses the Workers’ Compensation Board’s use of COVID‑19 prevalence and the nature of workplace contact to assess whether a claimant has suffered an “accidental injury.”
• No Requirement to Pinpoint a Single Exposure: Claimants need not identify the exact moment or specific person who infected them. Prolonged extraordinary exposure in the workplace, culminating in illness, can be an “accident” under the statute.
• Extraordinary Exposure is the Central Concept: Following Middleton and Johannesen, the Court holds that infections and environmental hazards are compensable when workplace exposure is significantly elevated above ordinary life.
• Robust Deference to the Board: The decision reinforces the minimal nature of substantial evidence review and the Board’s authority to choose among conflicting expert opinions.
• Consequential Injuries Recognized: Serious complications flowing from COVID‑19—here, a stroke—are compensable if supported by credible medical evidence linking them to the work‑related infection.

More broadly, Aungst situates COVID‑19 within New York’s established jurisprudence on workers’ compensation, rejecting the notion that pandemic infections defy traditional legal categories. Instead, it uses long‑standing doctrines—“common‑sense viewpoint,” “extraordinary exposure,” and “unusual environmental conditions”—to accommodate modern public health realities. The decision will guide resolution of pandemic and other infectious disease claims for years to come, marking a clear, precedent‑setting statement that the workers’ compensation system can and does respond to new forms of workplace risk using familiar legal tools.