Szymkowiak v. New York Power Auth.
Plaintiff Joseph Szymkowiak initiated a Labor Law and common-law negligence action against New York Power Authority for workplace injuries sustained in two accidents. Defendant moved for summary judgment to dismiss claims or limit damages, specifically regarding a second accident. The Supreme Court partially granted the motion but denied dismissal for the Labor Law § 240 (1) claim and post-concussion syndrome damages. On appeal, the Appellate Division modified the order, ruling that claims for post-concussion syndrome and a concussion condition were barred by collateral estoppel due to prior Workers' Compensation Board findings. However, the court affirmed the denial of summary judgment for the Labor Law § 240 (1) cause of action and allowed claims for headaches and the actual concussion to proceed.