Velazquez-Guadalupe v. Ideal Bldrs. & Constr. Servs., Inc.
The case Velazquez-Guadalupe v Ideal Bldrs. & Constr. Servs., Inc. addresses the scope of Workers' Compensation Law § 11 regarding third-party claims for contribution and indemnity against employers. The Appellate Division, Second Department, clarified that a Workers' Compensation Board (WCB) determination establishing an employer-employee relationship bars such claims, even if the third party did not participate in the WCB proceedings, overturning the Supreme Court's prior reliance on Baten v Northfork Bancorporation, Inc. The court granted CDW Carpentry, Inc. summary judgment on these cross-claims, as the WCB found it to be Velazquez-Guadalupe's employer. However, the court affirmed allowing defendants to assert a cross-claim for breach of an oral agreement to procure insurance against CDW, noting such agreements are distinct from indemnification, and affirmed denying JSK Construction Corp.'s summary judgment motion as premature for lack of discovery.