The principle of common-law, or implied, indemnification permits one who has been compelled to pay for the wrong of another to recover from the wrongdoer the damages it paid to the injured party. Evidence of a party's authority to supervise or direct work, without more, is insufficient to impose liability upon that party under a theory of common-law indemnification.
Chapa v. Bayles Props., Inc., NY Slip Op 06025 (2d Dep't November 22, 2023)