Owens v. Jea Bus Co., Inc.
The plaintiff, a school bus matron, sustained injuries in a collision and subsequently filed for workers' compensation benefits. The Workers' Compensation Board determined that Jea Bus Co., Inc. was her employer, and she began receiving benefits from their insurer. The plaintiff then commenced a personal injury action against Jea Bus Co., Inc., and Tebaldo A. Sibilia, the bus driver and a Smart Pick, Inc. employee. The defendants moved for summary judgment arguing the exclusivity provision of the Workers' Compensation Law. The Supreme Court denied this motion, finding triable issues of fact. The Appellate Division modified the order, granting summary judgment to Jea Bus Co., Inc., on the grounds of workers' compensation exclusivity, as the plaintiff had accepted benefits from them. However, the court denied summary judgment for Sibilia, finding he failed to establish prima facie that he was a special employee of Jea Bus Co., Inc., and thus not entitled to co-employee immunity.