Bach v. Millard Fillmore Health Systems, Inc.
This case addresses the applicability of the Omnibus Workers’ Compensation Reform Act of 1996 to a third-party action. The plaintiff was injured in July 1996, prior to the Act’s effective date of September 10, 1996. However, the subsequent third-party lawsuit against the employer, Amherst Acoustical, Inc., was initiated in November 1997, after the Act became law. The court examined whether the accident date or the lawsuit commencement date should dictate the application of the new legislation. Relying on the Court of Appeals' clear directive in Majewski v Broadalbin-Perth Cent. School Dist., the court ruled that irrespective of the accident date, a prospective application of the law to actions filed after the effective date requires dismissal of the third-party claim.