## Facts

- A large metal-shaping machine was manufactured in the late 1950s and sold to a New York purchaser through a New York sales agent that assisted with setup.
- The machine later reached a Missouri employer, which installed it at its Missouri plant and modified it by adding a foot switch.
- A Missouri employee was injured in Missouri while cleaning the running machine after a piece of wood had been wedged in the foot switch, preventing him from stopping it in time.
- The employee received Missouri workers’ compensation benefits.
- The employee sued the New York sales agent in New York on a products-liability theory.
- The New York defendant impleaded the Missouri employer, seeking contribution if the defendant were held liable.

## Issues

1. In a New York tort action, should Missouri’s workers’ compensation exclusivity statute be applied to bar a third-party contribution claim against a Missouri employer for a Missouri workplace injury to a Missouri employee?
2. Under New York choice-of-law principles for loss-allocation conflicts, do Missouri’s interests in enforcing its compensation bargain outweigh New York’s interest in permitting contribution among alleged tortfeasors?

## Decision

- The Court of Appeals affirmed dismissal of the third-party contribution claim against the Missouri employer.
- The court treated the conflict (employer immunity from contribution versus contribution availability) as loss-allocating rather than conduct-regulating.
- Applying New York’s interest analysis and the Neumeier rules, the court held Missouri law governed because the injury occurred in Missouri and the employee-employer relationship was centered there.
- The court concluded that allowing contribution in New York would indirectly impose liability on the Missouri employer contrary to Missouri’s statutory release from “all other liability” beyond workers’ compensation.

## Legal Principles

- Conflicts involving workers’ compensation exclusivity and contribution are generally loss-allocating and are analyzed differently from conduct-regulating rules.
- Under New York’s interest-analysis framework (including the Neumeier rules), when the place of injury and the relevant relationship are concentrated in a state, that state’s loss-allocation rules typically apply absent a strong countervailing policy.
- A state’s workers’ compensation exclusivity policy includes protecting employers from additional liability to employees and to third parties seeking contribution; other forums may give effect to that policy when the state has the dominant interest.

## Conclusion

Because the employee and employer were Missouri domiciliaries and the workplace accident occurred in Missouri, Missouri had the strongest interest in applying its workers’ compensation exclusivity scheme; New York therefore applied Missouri law and barred the New York defendant’s third-party contribution claim against the Missouri employer.


Cooney v. Osgood Mach., Inc., 81 N.Y.2d 66, 595 N.Y.S.2d 919, 612 N.E.2d 277 (1993)