Rucinski v. More Restoration Co., Inc.
Plaintiff Zbigniew Rucinski, an employee of subcontractor Skylights By George Co., Inc., sustained a traumatic brain injury while working at a property owned by Kraus Management Inc. and managed by Franklin Kite Housing Development Fund Corporation. The defendants, Kraus Management and Franklin Kite, moved for summary judgment for contractual indemnification against Skylights and opposed Skylights's motion to dismiss common-law indemnification and contribution claims. The Supreme Court conditionally granted defendants' motion for contractual indemnification but granted Skylights's motion to dismiss the common-law claims. The Appellate Division reversed this decision. It found that conflicting expert opinions on whether Rucinski suffered a 'grave injury' under Workers' Compensation Law § 11 created a triable issue of fact, thus precluding summary judgment for Skylights on the common-law claims. Furthermore, the Appellate Division determined that the defendants were entitled to unconditional summary judgment on their contractual indemnification claim against Skylights, as the contract did not require a finding of Skylights's negligence.