Caballero v. First Albany Corp.
Plaintiff, a former employee, appealed an order granting summary judgment to the defendant employer, dismissing her six causes of action. Her claims included gender discrimination, wrongful discharge, intentional infliction of emotional distress, assault and battery (due to secondhand smoke), unsafe workplace (Labor Law § 200), and civil rights discrimination (Civil Rights Law § 40-c), all stemming from alleged retaliation for her complaints about smoking in the office. The Appellate Division affirmed, finding the mistreatment was animus-based, not sexual discrimination. The court also held that her employment was at-will, her emotional distress claims lacked outrageous conduct, and her assault and battery and unsafe workplace claims were barred by Workers’ Compensation Law's exclusive remedy provisions.