In Northrop v. Thorsen, 46 AD3d 780, 848 N.Y.S.2d 304 (2d Dept. 2007), an attorney was found liable for legal malpractice for failing to comply with a Worker's Compensation rule that required either the carrier's consent or judicial approval to settle a third-party action and continue receiving compensation benefits. The Court found that the attorney's ignorance of the clearly established rule fell below any accepted standard of care. The Court further determined that the attorney's failure constituted negligence and proximately caused the plaintiff's injuries in that she could no longer receive Worker's Compensation benefits.