Theodoreu v. Chester Fire District
In this personal injury action, volunteer firefighter James Theodoreu, along with other plaintiffs, appealed a Supreme Court order granting summary judgment to defendants Chester Fire District and Sugar Loaf Engine Company, Inc. The appellate court affirmed the dismissal, holding that the Volunteer Firefighters’ Benefit Law § 19 provides an exclusive remedy for injuries sustained in the line of duty, thereby barring claims against the fire district (as a political subdivision) and the fire company (due to an employer/employee relationship). Additionally, the defendant Witfield Architectural Group's cross-claims against the fire district and fire company were properly dismissed. This dismissal was based on Witfield's failure to demonstrate that the injured plaintiff suffered a "grave injury," a prerequisite for employer liability under Workers’ Compensation Law § 11 for contribution or indemnity.