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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

Chatelain v. Mount Sinai Hospital

Plaintiff, discharged from Mount Sinai Hospital for misconduct, was denied unemployment benefits by the New York State Department of Labor. Though the administrative decision was upheld on appeal, plaintiff did not pursue state court review but instead filed a federal action alleging wrongful discharge and breach of duty of fair representation. Defendant moved for summary judgment, asserting collateral estoppel based on the administrative ruling. The District Court denied defendant's motion and granted plaintiff's cross-motion to strike the collateral estoppel defense, holding that administrative agency decisions not reviewed by a state court, especially those from potentially unfair hearings, should not be given preclusive effect in federal court actions under the Labor Management Relations Act.

Wrongful DischargeCollateral EstoppelRes JudicataUnemployment BenefitsAdministrative LawFederal Court JurisdictionLabor Management Relations ActDue ProcessSummary JudgmentGrievance Procedures
References
8
Case No. MISSING
Regular Panel Decision
Oct 22, 1980

Hilowitz v. Hilowitz

In a negligence action for personal injuries, the plaintiff appealed an order from the Supreme Court, Queens County, dated October 22, 1980. The order, issued by Justice Hyman, had denied the plaintiff's motion to dismiss the defense of collateral estoppel. The appellate court affirmed the order, holding that an arbitration award, even without judicial confirmation, can serve as a basis for res judicata and collateral estoppel if there was a final determination on the merits. The court referenced Kilduff v Donna Oil Corp. and distinguished Hana Heating & Air Conditioning Co. v Sheet Metal Workers Int. Assn. All other contentions raised by the plaintiff were deemed to be without merit.

NegligencePersonal InjuryAppealCollateral EstoppelRes JudicataArbitration AwardJudicial ConfirmationFinal DeterminationAppellate DecisionSupreme Court Order
References
4
Case No. MISSING
Regular Panel Decision

Harrison v. Celotex Corp.

This is a products liability action where the plaintiff alleges her husband was fatally injured due to exposure to asbestos-containing products manufactured and sold by the defendants. The plaintiff filed a motion for partial summary judgment, seeking to apply offensive nonmutual collateral estoppel against four defendants (GAF Corp., Pittsburgh-Corning Corp., Celotex Corp., and Fibreboard Corp.) based on a prior judgment in another case, Richardson v. Johns-Manville Sales Corp. The Court first determined that federal law, rather than state law, of issue preclusion applies in this diversity case. Ultimately, the motion was denied because the application of offensive collateral estoppel would be unfair to the defendants due to the presence of prior inconsistent judgments in similar asbestos cases.

Products LiabilityAsbestosCollateral EstoppelIssue PreclusionDiversity JurisdictionFederal LawState LawOffensive Collateral EstoppelNonmutual PreclusionInconsistent Judgments
References
32
Case No. MISSING
Regular Panel Decision

Bowen ex rel. Doe v. Arnold

The Supreme Court of Tennessee addressed whether a person convicted of rape and aggravated sexual battery is collaterally estopped from relitigating these issues in a subsequent civil lawsuit filed by the victim. The trial court had applied collateral estoppel, granting partial summary judgment to the victim. The Court affirmed this decision, abolishing the strict party mutuality requirement for both offensive and defensive collateral estoppel in Tennessee. The Court adopted sections 29 and 85 of the Restatement (Second) of Judgments as guidelines. This was reasoned by the Court that the defendant had a full and fair opportunity to litigate the issue in the prior criminal trial, and no circumstances warranted relitigation in the civil action.

Collateral EstoppelIssue PreclusionOffensive Collateral EstoppelDefensive Collateral EstoppelParty Mutuality RequirementRestatement (Second) of JudgmentsCriminal Conviction in Civil CaseSummary JudgmentRapeAggravated Sexual Battery
References
88
Case No. M2015-00762-SC-R11-CV
Regular Panel Decision
Sep 29, 2016

Ms. Bowen Ex Rel. John Doe, N v. William E. Arnold, Jr.

This appeal addresses whether a criminal conviction for rape and aggravated sexual battery can collaterally estop a defendant from relitigating these issues in a subsequent civil lawsuit filed by the victim. The trial court applied collateral estoppel, which was challenged by the defendant on grounds of lacking party mutuality and differing issues between criminal and civil proceedings. The Supreme Court of Tennessee abolished the strict party mutuality requirement for both offensive and defensive collateral estoppel, adopting sections 29 and 85 of the Restatement (Second) of Judgments as guiding principles. Applying these new guidelines, the Court affirmed the trial court's grant of partial summary judgment against the defendant. This decision prevents the defendant from relitigating the issues of whether he raped and sexually battered the minor plaintiff in the ongoing civil action.

Collateral EstoppelNonmutual Collateral EstoppelOffensive Collateral EstoppelDefensive Collateral EstoppelCriminal ConvictionCivil LawsuitRapeAggravated Sexual BatteryRes JudicataJudicial Economy
References
82
Case No. MISSING
Regular Panel Decision
May 21, 2001

Lozada v. GBE Contracting Corp.

Klever Lozada, a plaintiff, was injured after falling from a truck while painting a highway bridge. He and other plaintiffs initially brought an action against the State of New York and GBE Contracting Corp., the general contractor. A prior ruling in the Court of Claims, which initially granted Lozada an interlocutory judgment under Labor Law § 240 (1), was reversed on appeal, concluding that Lozada was a recalcitrant worker and his own conduct was the sole proximate cause of his injuries. Subsequently, GBE Contracting Corp. moved for summary judgment in the Supreme Court action, citing collateral estoppel based on the appellate reversal. The Supreme Court granted the motion, dismissing the complaint, and the appellate court affirmed, holding that the issue of Lozada's sole proximate cause had been previously decided, thus precluding relitigation.

Collateral EstoppelRecalcitrant WorkerSummary JudgmentLabor LawPersonal InjuryAppealsProximate CauseDamagesQueens CountySupreme Court
References
9
Case No. No. 37
Regular Panel Decision
Apr 25, 2024

Suzan Russell v. New York University

Plaintiff, an adjunct professor at NYU, was subjected to offensive conduct by colleagues and subsequently sued them and her employer in federal court, alleging violations of federal, New York State, and New York City statutes, along with intentional infliction of emotional distress. The federal court granted summary judgment to the defendants on the federal claims and declined supplemental jurisdiction over the state and city claims, a decision upheld by the Second Circuit. Plaintiff then initiated a nearly identical suit in state Supreme Court, Bronx County, which dismissed her complaint based on collateral estoppel and failure to state a claim. The Appellate Division affirmed this dismissal, and the Court of Appeals now affirms, holding that collateral estoppel bars plaintiff's claims and that the City Human Rights Law does not permit individual coworker liability without a supervisory role.

Collateral EstoppelHostile Work EnvironmentDiscrimination LawRetaliation ClaimsSummary JudgmentNew York City Human Rights Law (NYCHRL)New York State Human Rights Law (NYSHRL)Individual Employee LiabilityFederal Court JurisdictionAppellate Review
References
88
Case No. MISSING
Regular Panel Decision

Rigopolous v. American Museum of Natural History

The case examines the application of collateral estoppel stemming from a workers’ compensation proceeding. The court found that collateral estoppel correctly barred the plaintiff's Labor Law § 240 (1) claim, affirming the lower court's dismissal of that specific cause of action. However, the Supreme Court erred in applying collateral estoppel to the plaintiff’s claims of negligence and violations of Labor Law §§ 200 and 241 (6), as the prior workers' compensation determination was too narrow. Consequently, the appellate court modified the order to reinstate the negligence and Labor Law §§ 200 and 241 (6) causes of action, citing the defendant's failure to eliminate all triable issues of fact.

Collateral EstoppelWorkers' CompensationSummary JudgmentLabor Law §240Labor Law §200Labor Law §241NegligenceIssue PreclusionAppellate ReviewJudicial Error
References
12
Case No. MISSING
Regular Panel Decision

Claim of Acunzo v. Newsday, Inc.

The claimant, a district circulation manager for Newsday, Inc., sustained a back injury in 1981 while unloading newspapers. After initially receiving payments and returning to work, he retired in 1982 and subsequently sought workers' compensation benefits, claiming his injury necessitated his retirement. A Workers' Compensation Law Judge awarded benefits, which the employer appealed, arguing collateral estoppel based on a prior unemployment insurance denial. The Workers' Compensation Board rejected the collateral estoppel argument, differentiating between requiring retirement and being a factor in it, and referred the case for further evidence on disability and its causal link to retirement. The appellate court ultimately dismissed the employer's appeal as nonfinal, concluding that the underlying substantive issues had not been fully resolved and the collateral estoppel issue was not dispositive.

Workers' CompensationBack InjuryRetirementCollateral EstoppelNonfinal OrderAppeal DismissedDisabilityCausal RelationshipUnemployment InsuranceWorkers' Compensation Board
References
5
Case No. MISSING
Regular Panel Decision

Anders v. Mallard and Mallard, Inc.

Appellants, including Donnel Ray Anders, sued Mallard and Mallard, Inc. in Harris County, alleging negligence, gross negligence, conspiracy, failure to warn, and violation of Tex.Water Code Ann. § 11.086 due to property flooding caused by a dam/roadway and its subsequent breaches. The trial court granted Mallard's motion for summary judgment based on statute of limitations, res judicata, and collateral estoppel. The appellate court reversed the summary judgment regarding limitations for temporary damages within a two-year period prior to filing suit. It also partially sustained and overruled the points on res judicata and collateral estoppel, finding that collateral estoppel barred relitigation of negligent dam design/construction, but not other issues. The case is remanded for further proceedings.

Summary JudgmentStatute of LimitationsRes JudicataCollateral EstoppelNegligenceGross NegligenceCivil ConspiracyFloodingProperty DamageWater Code
References
11
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