Correa v. Anderson
Plaintiff Leeanne M. Correa and a coworker (defendant) were employed as exercise riders. Plaintiff was injured when an anvil fell from defendant's SUV after he offered her a hat and handed her the keys, leading her to open the tailgate. Plaintiff and her husband commenced a negligence action. The Supreme Court granted defendant's motion for summary judgment, dismissing the complaint, citing the exclusivity provisions of the Workers’ Compensation Law. Plaintiffs appealed, arguing defendant was not acting within the scope of his employment when the injury occurred. The appellate court affirmed, ruling that because defendant's act of lending a hat to a coworker provided a slight advantage to the employer and was work-related, he was acting within the scope of employment, triggering the Workers' Compensation Law's exclusivity.