NGM Ins. Co. v. MGC Design & Constr. Corp.
NGM Insurance Company initiated a declaratory judgment action to determine if it was obligated to defend or indemnify MGC Design & Construction Corp. in an underlying action stemming from a construction worker's trip and fall injury. The central dispute revolved around whether the worker, Carlos Guichay, sustained a "grave injury" as defined by Workers' Compensation Law § 11 (1), which would negate the employer's statutory shield from third-party liability. The Supreme Court granted NGM's motion for summary judgment, concluding that no grave injury occurred. The Appellate Division, Second Department, affirmed this decision, finding that the construction manager, IE Construction Management, LLC, failed to present a triable issue of fact and that medical evaluations indicated Guichay remained employable in some capacity, precluding a finding of "permanent total disability."