THOMAS, PIA v. DUNKIRK RESORT PROPERTIES, LLC
Plaintiff commenced an action to recover damages for injuries sustained during employment at a hotel owned by defendant Dunkirk Resort Properties, LLC (Dunkirk Resort) and managed by her employer, nonparty S & K Hospitality, LLC (S & K). The Supreme Court erred in granting Dunkirk Resort's motion for summary judgment. The court rejected the out-of-possession landlord standard as applied by the lower court because no leasehold was created by the agreement between Dunkirk Resort and S & K; rather, it was a management agreement. Additionally, Dunkirk Resort's submissions raised a triable issue of fact regarding its out-of-possession landlord status. Furthermore, Dunkirk Resort failed to establish the applicability of the Workers’ Compensation Law § 11 exclusivity provision, as triable issues of fact remain concerning whether Dunkirk Resort is the alter ego of S & K, given their distinct purposes, bank accounts, and tax returns despite shared members.