Phillips v. Taco Bell Corp.
The plaintiff, Rachina Phillips, sustained personal injuries after boiling water spilled on her right foot while preparing hot foods within the scope of her employment at a Taco Bell restaurant. She initiated an action against Taco Bell Corp. and Yum! Brands, Inc., alleging negligence. The defendants moved to dismiss the complaint, asserting that the plaintiff's employer, Taco Bell of America, LLC, was a subsidiary or sister company and that workers' compensation was the exclusive remedy, or that they lacked ownership/control over the premises. The Supreme Court denied this motion. The Appellate Division affirmed the Supreme Court's order, determining that the affidavits submitted by the defendants did not qualify as documentary evidence under CPLR 3211 (a)(1) and failed to conclusively establish a defense or refute the plaintiff's factual allegations for both CPLR 3211 (a)(1) and (7).