Anastasia v. Barnes
This case involves a wrongful death action where the defendant, New York Racing Association, Inc. (NYRA), and third-party defendant, Pinkerton’s New York Racing Security Service, Inc., moved to amend their answers. They sought to assert a setoff for pension and insurance benefits received by the plaintiff due to the decedent's death, invoking the "collateral source rule." The court, presided over by Justice Kenneth H. Lange, denied both motions. The decision delves into the nuances of the collateral source rule, distinguishing between gratuitous benefits and those part of employment compensation. It concludes that NYRA, not having contributed to the benefits, cannot assert them as a setoff, and Pinkerton’s, despite funding some benefits, cannot use them against an indemnification claim, prioritizing the tort-feasor's responsibility for compensation.