Pereira v. St. Joseph's Cemetery
The plaintiff, a cemetery worker named Pereira, appealed an order from the Supreme Court, Westchester County, which dismissed his personal injury complaint against St. Joseph’s Cemetery, Church of St. Joseph, and the Archdiocese of New York, based on res judicata. Pereira had previously filed a similar action alleging intentional tort, but it was dismissed on appeal because the allegations did not meet the intentional tort exception to Workers' Compensation Law § 29. In the current second action, Pereira rephrased his intentional tort allegations, and the defendants again moved to dismiss, this time citing res judicata, which the Supreme Court granted. The appellate court reversed the Supreme Court's decision, ruling that a prior dismissal for failure to state a cause of action is generally not on the merits and therefore does not trigger the doctrine of res judicata. Consequently, the appellate court denied the defendants' motion to dismiss, allowing the plaintiff's second action to proceed.