Ray v. Knights
This case involves an automobile accident in Ulster County, New York, where a plaintiff passenger was injured in a vehicle operated by defendant Glenn W. Tynan, which collided with a vehicle owned by Eastern Ingredients and operated by David W. Knights. The plaintiff sued Tynan, Knights, and Eastern for negligence. Tynan initially argued the exclusivity of workers' compensation, having received payments from Tynan's carrier. However, the New Jersey Workers’ Compensation Court subsequently determined that the accident did not occur in the course of the plaintiff's employment, rendering the injuries non-compensable under workers' compensation. The court reversed the Supreme Court's decision to dismiss claims against Tynan, ruling that the plaintiff's acceptance of voluntary payments did not bar a direct action, as there was no election between mutually exclusive remedies. Furthermore, concerning contribution claims, the court applied New York law over New Jersey law, allowing Knights and Eastern to assert cross-claims against Tynan in the event the workers' compensation decision is overturned.