Siekkeli v. Mark Mariani, Inc.
In an action for personal injuries, plaintiff Mika P. Siekkeli was allegedly injured while working at Mark Mariani, Inc., when a heavy door fell on him. He sued Mariani and Mark Varley. Mariani then filed a third-party action against its insurance broker, Frank Crystal & Co., alleging inadequate coverage. The Supreme Court denied summary judgment motions by Varley and Mariani, citing triable issues regarding Siekkeli's employment status, but granted Crystal's motion for summary judgment. The Appellate Division reversed the order, finding that the Workers' Compensation Board has primary jurisdiction to determine employment status and that the Supreme Court erred in granting Crystal's motion.