Melo v. Jewish Board of Family & Children's Services, Inc.
Plaintiff Evelyn Melo, an employee of Jewish Board of Family and Children’s Services, Inc. (JBFCS), filed a tort action after sustaining personal injuries from an attack, rape, and robbery at her workplace. JBFCS moved to dismiss the complaint, asserting that the Workers' Compensation Law provides the exclusive remedy for such injuries. Melo cross-moved, arguing that her injuries were not "accidental workplace injuries" and therefore fell outside the purview of workers' compensation. The court analyzed the Workers' Compensation Law, specifically §§ 10, 11, and 21, and relevant case law regarding "accidental injury" and its exceptions. The court determined that Melo was indeed an employee, the incident occurred during her employment, and she failed to demonstrate that the Workers' Compensation Law did not preempt her tort action. The court granted JBFCS's motion to dismiss and denied Melo's cross-motion, also awarding costs to the defendant.