Poppenberg v. Reliable Maintainance Corp.
In this negligence action, the plaintiff sued Reliable Maintenance Corporation for injuries sustained due to a defective elevator. Reliable moved for summary judgment, asserting an affirmative defense that the action was barred by Workers’ Compensation Law § 11, arguing that the plaintiff was either an employee of a joint venture involving Reliable and Suburban Maintenance Corporation or a special employee of Reliable. Special Term denied the motion, citing unresolved questions of fact regarding the plaintiff's employment status. The appellate court affirmed the denial of summary judgment, finding no evidence of a joint venture due to the lack of shared profits and losses among the corporations, despite common ownership. The court also concluded that there were insufficient facts to determine control over the plaintiff for either joint or special employment, necessitating a trial for full factual development.