Williams v. Beth Israel Hosp. Assn.
Lisa Williams, an employee of a staffing agency assigned to Beth Israel Medical Center, filed a negligence claim after a trip and fall incident. Beth Israel Medical Center moved for summary judgment, arguing that Williams's sole remedy was under the Workers' Compensation Law due to a special employer relationship, and that they lacked actual or constructive notice of the dangerous condition. The Supreme Court denied the motion to dismiss and for summary judgment but granted leave to amend the answer. The Appellate Division affirmed the Supreme Court's order, concluding that Beth Israel Medical Center failed to demonstrate a clear surrender and assumption of control for the special employer defense and did not establish a prima facie lack of constructive or actual notice.