Psaras v. GCA Services Group
Justice James Pagones
Third-party defendant Stryker Orthopaedics moved to apply New Jersey law to the third-party action and dismiss the third-party complaint. GCA Services Group consented to application of New Jersey law to the issue of Stryker's liability, but opposed dismissal of this personal injuries action arising from an alleged trip and fall while Psaras was working at Stryker's New Jersey facility. Psaras received Workers' Compensation benefits under New Jersey's Workers' Compensation Act (WCA), and sued GCA, the company that contracted with Stryker to clean its New Jersey office. The WCA provided the exclusive remedy by which employees could recover for workplace injuries, unless the case satisfied the statutory exception for an intentional wrong, interpreted as requiring a "substantial certainty" that injury would occur. The court found Stryker established prima facie that it did not engage in any intentional conduct leading to Psaras' alleged injuries. It noted Psaras' alleged accident, tripping and falling on boxes in a storage room, was not beyond what was contemplated by the legislature "as part and parcel of workplace hazards" intended to be covered by WCA. Thus, Stryker's motion was granted and the third-party complaint dismissed.