Hart v. Sullivan
Plaintiff June Hart appealed an order denying a motion to dismiss her complaint against P & C Food Markets, Inc., and two managerial employees, Kenneth Sullivan and Mike Buker. Hart alleged intentional infliction of emotional distress due to sexual advances by Sullivan and Buker, and sex discrimination by the corporate defendant under Executive Law § 296. She also included a derivative claim for her husband. The court modified the order, dismissing the intentional tort claim against the employer due to the Workers' Compensation Law's exclusivity provision, as no willful act by the employer was alleged. The husband's derivative claim was also barred. Furthermore, the sex discrimination claim against the employer was dismissed because respondeat superior does not apply in such cases without allegations of the employer's knowledge or acquiescence.