Garcia v. Monadnock Constr., Inc.

Summary

The Court of Appeals affirmed the Appellate Division and held that the Justice For Injured Workers Act prohibited Supreme Court, after the Act's effective date, from giving collateral estoppel effect to a prior Workers' Compensation Board determination, except as to the existence of an employer-employee relationship. Applying the statute after its effective date was prospective rather than retroactive because it did not impair rights, increase liability for past conduct, or impose new duties concerning completed transactions. Supreme Court therefore erred in granting defendants' motion based on collateral estoppel.