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Keywords

lawsuittortdefendantworkers' compensationsustained
tortplaintiffdefendantappealworkers' compensation

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Martin v. Casagrande, 159 A.D.2d 26, 559 N.Y.S.2d 68

Facts

Richard Martin, a former professional hockey player, sustained a knee injury during a game on November 9, 1980. He was examined by the team physician, Dr. Casagrande, who diagnosed a sprained knee. After missing several games and undergoing surgery, Martin later sought a second opinion, which revealed more severe damage. He filed a lawsuit against the Buffalo Sabres, their general manager, and the team doctor, alleging intentional torts related to the concealment of his injury's severity. The court ultimately dismissed his claims, citing workers' compensation as his exclusive remedy.

Martin was immediately examined by Dr. Casagrande, the Sabres team physician and an orthopedic specialist for over 30 years. He found no evidence of swelling or fracture and made a preliminary diagnosis of a sprained knee due to hyperextension.

Issue

Whether an employee whose injury has been determined to be compensable by the Workers' Compensation Board and who has accepted workers' compensation benefits is barred from bringing a direct action for intentional tort against his employer.

The central issue presented on this appeal is whether an employee whose injury has been determined to be compensable by the Workers' Compensation Board and who has accepted workers' compensation benefits is barred from bringing a direct action for intentional tort against his employer.

Rule

Under New York law, if an employee has received workers' compensation benefits for an injury deemed compensable by the Workers' Compensation Board, that employee is barred from pursuing a direct action for intentional tort against the employer. This exclusivity rule is grounded in the principle that the workers' compensation remedy is the sole recourse for employees injured in the course of their employment.

By accepting an award of workers' compensation benefits, plaintiff forfeited his right to maintain an action at law on the theory of intentional tort.

Analysis

In this case, the Workers' Compensation Board had already determined that Martin's knee injury was compensable and occurred during his employment with the Sabres. By accepting workers' compensation benefits, Martin forfeited his right to pursue an intentional tort claim. The court found no evidence of intentional concealment or fraud by the defendants, and since the employer's actions did not rise to the level of an intentional tort, the exclusivity of the workers' compensation remedy applied.

Since the Workers' Compensation Board found plaintiff's injury compensable and ordered reimbursement to plaintiff's employer (the Sabres), plaintiff is barred from now arguing that he was not an employee of the Sabres at the time of the accident causing his injury.

Conclusion

The court affirmed the dismissal of Martin's claims, holding that he was barred from pursuing an intentional tort claim due to the exclusivity of workers' compensation as his remedy.

We affirm, but for reasons other than those relied upon by Supreme Court.

Who won?

The Buffalo Sabres and their general manager prevailed in this case because the court found that Martin's claims were barred by the exclusivity of the workers' compensation remedy. The court determined that Martin had received workers' compensation benefits for his injury, which was deemed compensable by the Workers' Compensation Board. As a result, he could not maintain a direct action for intentional tort against his employer or its representatives.

The court held that Martin was an employee of the Sabres and that plaintiff did not meet his burden of establishing defendants' intentional tortious conduct to avoid the exclusivity of workers' compensation.

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