Clarke v. Laidlaw Transit, Inc.
The plaintiff, an employee of First Student Management, LLC (FSM), allegedly was injured when she fell due to a defective condition at FSM's place of business. She commenced an action against Laidlaw Transit, Inc., the record owner of the premises. The defendant moved to dismiss the complaint, asserting it had merged with First Student, Inc., and that First Student and FSM were functionally the same entity under Workers' Compensation Law exclusivity provisions. The plaintiff cross-moved to amend the caption to name the defendant as "First Student, Inc. f/k/a Laidlaw Transit, Inc." The Supreme Court granted the defendant's motion and denied the plaintiff's cross-motion. The Appellate Division reversed the Supreme Court's order, denying the defendant's motion to dismiss and granting the plaintiff's cross-motion, finding the defendant's documentary evidence did not conclusively establish a defense and that the proposed amendment was not palpably insufficient or prejudicial.