Marpe v. Dolmetsch
This case involves cross appeals from an order of the Supreme Court in Rensselaer County. The plaintiff, a former employee of Capital Area Community Health Plan (CHP), alleged sexual misconduct and harassment by her therapist and supervisor, Paul Dolmetsch, also employed by CHP. The original complaint included claims against Dolmetsch for sexual harassment, negligent/intentional infliction of emotional distress, prima facie tort, battery, and assault, and against CHP for sexual harassment/discrimination and vicarious liability. Plaintiff sought to amend her complaint to add a medical malpractice claim against Dolmetsch and a negligent supervision claim against CHP. The appellate court affirmed the Supreme Court's decision, finding the medical malpractice claim related back to the original complaint and the negligent supervision claim lacked evidentiary merit.