Horn v. N.Y. Times

In Horn v. N.Y. Times (100 NY2d 85, 95, 790 N.E.2d 753, 760 N.Y.S.2d 378 [2003]), the Court of Appeals further explained that this circumstance exists when certain related factors are found, specifically when there is a centrality of purpose between the employee and employer's enterprise; when self-regulation to the employer's industry is critical; and the employee and employer have a mutual obligation to abide by the particular statute or policy rule (100 NY2d at 95-97).