Bryant v. Gulnick
Plaintiff Carla F. Bryant was injured in a vehicle accident involving Barbara A. Hyde, a volunteer for Jewish Family Services of Ulster County, Inc. (JFS). Bryant, also a County employee, had previously sought workers' compensation benefits, and a 2019 order determined she and Hyde were coemployees, making workers' compensation her exclusive remedy. Bryant sued Hyde's estate and JFS, alleging Hyde's negligence and JFS's vicarious liability. The Supreme Court dismissed the claim against Hyde's estate based on collateral estoppel from the 2019 order but denied JFS's motion to dismiss and instead granted partial summary judgment to Bryant against JFS. The Appellate Division, Third Department, reversed, finding that collateral estoppel applied to the coemployee issue, thus barring Bryant's derivative action against JFS. Consequently, the court granted JFS's motion for summary judgment and dismissed the complaint against it, and denied Bryant's motion for partial summary judgment on liability.