Power v. Frasier
Joseph Power, an employee of the New York City Transit Authority, and his wife, sought damages for personal injuries sustained when Power was struck by a vehicle driven by coemployee John Frasier in a parking lot. Power had received workers' compensation benefits for his injuries. The defendants, John Frasier and his father Edward M. Frasier, moved for summary judgment, arguing the action was barred by the exclusivity provisions of the Workers' Compensation Law. The Supreme Court granted their motion, and the Appellate Division affirmed, holding that the Workers' Compensation Law provides an exclusive remedy when both parties are coemployees acting within the scope of their employment. Since John Frasier was found to be acting within the scope of his employment, he was immune from direct liability, and his father could not be held vicariously liable.