Cusano v. Staff
Plaintiff, a secretary, sued the owner of her office building for injuries sustained from a fall on ice and snow in the parking lot. The defendant, who was also the principal stockholder and managing officer of the plaintiff's employer, moved for summary judgment, claiming immunity as a coemployee under Workers' Compensation Law § 29 (6). The Supreme Court denied this motion, concluding the defendant's alleged tortious conduct was in his capacity as a property owner, not a coemployee. On appeal, the court affirmed, holding that coemployee immunity is limited to acts within the scope of employment. In this case, the defendant's duty of care arose purely from his role as the property owner, as the accident occurred in a common parking area not controlled by the employer.