Vazquez v. Orange County Rehabilitation Center
Plaintiff's ward was allegedly sexually assaulted by defendant Lewis while engaged in piecework at a sheltered workshop operated by Occupations. Defendants Occupations and Lewis asserted workers' compensation coverage as affirmative defenses. The court held that claims occurring before July 22, 1989, when Mental Hygiene Law § 33.09 (c) excluded sheltered workshop participants from workers' compensation, are not subject to the defense. For claims after July 22, 1989, when the law was amended to allow coverage if elected, the issue of workers' compensation coverage is referred to the Workers' Compensation Board. Defendant Orange County Department of Mental Health's motion for summary judgment was granted due to lack of evidence linking them to the incident or supervision of Occupations.