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MISLEVELED SIDEWALK WAS A NON-ACTIONABLE TRIVIAL DEFECT.

The Second Department, in this slip and fall case, determined the misleveled sidewalk was an non-actionable trivial defect:

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“A defendant seeking dismissal of a complaint on the basis that the alleged defect is trivial must make a prima facie showing that the defect is, under the circumstances, physically insignificant and that the characteristics of the defect or the surrounding circumstances do not increase the risks it poses. Only then does the burden shift to the plaintiff to establish an issue of fact” … . Here, the defendant established, prima facie, that the alleged defect that caused the injured plaintiff to fall was trivial and therefore not actionable. In support of its motion, the defendant relied upon, inter alia, the injured plaintiff’s deposition transcript, as well as photos identified and marked by the injured plaintiff showing in detail the alleged defect as it existed at the time of the subject accident. Considering the photographs, which showed the height and extent of the alleged defect, along with the injured plaintiff’s description of the time, place, and circumstance of the injury, the defendant established, prima facie, that the alleged defect was trivial as a matter of law and, therefore, not actionable … . Fasone v Northside Props. Mgt. Corp., 2017 NY Slip Op 02966, 2nd Dept 4-19-17

NEGLIGENCE (SLIP AND FALL, MISLEVELED SIDEWALK WAS A NON-ACTIONABLE TRIVIAL DEFECT)/SLIP AND FALL (SLIP AND FALL, MISLEVELED SIDEWALK WAS A NON-ACTIONABLE TRIVIAL DEFECT)/SLIP AND FALL (SLIP AND FALL, MISLEVELED SIDEWALK WAS A NON-ACTIONABLE TRIVIAL DEFECT)/TRIVIAL DEFECT (SLIP AND FALL, MISLEVELED SIDEWALK WAS A NON-ACTIONABLE TRIVIAL DEFECT)

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LOCAL LAWS CONCERNING PROCEDURES TO BE FOLLOWED BY THE VILLAGE ZONING BOARD OF APPEALS WERE NOT PREEMPTED BY THE STATE-WIDE VILLAGE LAW.

The Second Department determined the local procedural laws for the zoning board of appeals (ZBA) were not preempted by the state-wide Village Law and the village’s failure to comply with time limits imposed by the local laws did not require the annulment of the board’s ruling (approving a variance). The decision includes a good discussion of the interplay between local zoning laws and the state-wide Village Law:

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“Although local laws that are inconsistent with state laws are generally invalid, the Municipal Home Rule Law allows incorporated villages to amend or supersede provisions of the Village Law as they relate to zoning matters” … . Nevertheless, “[l]ocal lawmaking power under the supersession authority is of course in all instances subject to the State’s transcendent interest where the Legislature has manifested such interest by expressly prohibiting a local law, or where a local law is otherwise preempted by State law” … .

Here, contrary to the petitioner’s contention, Village Law § 7-712-a does not preempt the Village from regulating the issues of whether its ZBA renders short-form or long-form decisions, or the time periods within which those decisions must be issued. The Legislature has not evinced an intent to preempt the field, and the legislative history of that section indicates that the Legislature envisioned no comprehensive and detailed regulatory scheme with respect to the form or timing of decisions of a zoning board of appeals … . Matter of Wenz v Brogan, 2017 NY Slip Op 03009, 2nd Dept 4-19-17

 

ZONING (LOCAL LAWS CONCERNING PROCEDURES TO BE FOLLOWED BY THE VILLAGE ZONING BOARD OF APPEALS WERE NOT PREEMPTED BY THE STATE-WIDE VILLAGE LAW)/PREEMPTION (ZONING, LOCAL LAWS CONCERNING PROCEDURES TO BE FOLLOWED BY THE VILLAGE ZONING BOARD OF APPEALS WERE NOT PREEMPTED BY THE STATE-WIDE VILLAGE LAW)

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DEFENDANT DID NOT DEMONSTRATE A LOAN WAS ORALLY CONVERTED TO A GIFT BY DECEDENT, CRITERIA FOR PROOF OF A GIFT EXPLAINED.

The Second Department determined the claim that a loan made by decedent was orally converted to a gift (by the decedent) was not demonstrated. The proof sufficient to prove a gift was laid out by the court:

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… [T]he plaintiff submitted evidence that the decedent made a loan to the defendant in February 2010 for $50,000, which he did not repay. Contrary to the determination of the court, the defendant’s testimony at his deposition that the decedent told him in 2012 that the loan was “a gift,” without more, does not raise a material issue fact sufficient to defeat the plaintiff’s entitlement to judgment. “It has long been the rule in this State that a debt owing from one party to another will not, by a mere oral declaration subsequently made, be transformed from a debt to a gift” … . To make a valid gift, ” the donor must intend to make an irrevocable present transfer of ownership, there must be delivery of the gift, either by physical delivery of the subject of the gift or a constructive or symbolic delivery, and there must be acceptance by the donee”‘ … . “[I]n the case of an oral gift, the fact of delivery serves to assist, in an evidentiary manner, to confirm the intent of the donor, and to prevent the assertion of fraudulent claims” … . Thus, while the defendant’s allegation provides evidence of the decedent’s intent to make a gift of the loan amount, it provides no evidence that the gift was delivered and, consequently, that the gift took effect … . Scotti v Barrett, 2017 NY Slip Op 03031, 2nd Dept 4-19-17

TRUSTS AND ESTATES (DEFENDANT DID NOT DEMONSTRATE A LOAN WAS ORALLY CONVERTED TO A GIFT BY DECEDENT, CRITERIA FOR PROOF OF A GIFT EXPLAINED)/GIFTS (TRUSTS AND ESTATES, DEFENDANT DID NOT DEMONSTRATE A LOAN WAS ORALLY CONVERTED TO A GIFT BY DECEDENT, CRITERIA FOR PROOF OF A GIFT EXPLAINED)

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COUNTY’S MOTION FOR SUMMARY JUDGMENT PROPERLY DENIED, PLAINTIFFS ALLEGED FAILURE TO CLEAN UP LOOSE GRAVEL IN A BIKE PATH AFTER PATCHING A HOLE CAUSED THE BICYCLE ACCIDENT.

The Second Department determined defendant county was not entitled to summary judgment in this bicycle accident case. Plaintiffs alleged the county left loose gravel in the bike path after patching a hole (the loose gravel allegedly caused the accident). The written notice requirement did not apply because it was alleged the county created the dangerous condition. The primary assumption of the risk doctrine did not apply, The defect was not demonstrated to be trivial. The open and obvious defense applies only to the duty to warn, not the duty to make the property safe:

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The plaintiffs alleged, inter alia, that the County defendants affirmatively created the dangerous condition by leaving excess patching material at the scene of the repair. Affirmative creation is an exception to the County’s prior written notice ordinance  … . Thus, in order to establish their prima facie entitlement to judgment as a matter of law, the County defendants were required to submit evidence that they did not affirmatively create the defect as the plaintiffs alleged … . The County defendants failed to meet this burden … . Fornuto v County of Nassau. 2017 NY Slip Op 02969, 2nd Dept 4-19-17

NEGLIGENCE (COUNTY’S MOTION FOR SUMMARY JUDGMENT PROPERLY DENIED, PLAINTIFFS ALLEGED FAILURE TO CLEAN UP LOOSE GRAVEL IN A BIKE PATH AFTER PATCHING A HOLE CAUSED THE BICYCLE ACCIDENT)/MUNICIPAL LAW (WRITTEN NOTICE REQUIREMENT DID NOT APPLY, COUNTY’S MOTION FOR SUMMARY JUDGMENT PROPERLY DENIED, PLAINTIFFS ALLEGED FAILURE TO CLEAN UP LOOSE GRAVEL IN A BIKE PATH AFTER PATCHING A HOLE CAUSED THE BICYCLE ACCIDENT)/OPEN AND OBVIOUS DEFENSE (APPLIES ONLY TO DUTY TO WARN, NOT DUTY TO KEEP PROPERTY SAFE, COUNTY’S MOTION FOR SUMMARY JUDGMENT PROPERLY DENIED, PLAINTIFFS ALLEGED FAILURE TO CLEAN UP LOOSE GRAVEL IN A BIKE PATH AFTER PATCHING A HOLE CAUSED THE BICYCLE ACCIDENT)

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APPLICATION TO ADD HANDGUNS TO PISTOL PERMIT PROPERLY DENIED BASED UPON PETITIONER’S CRIMINAL HISTORY, DECLARATORY JUDGMENT ACTION IS THE PROPER PROCEEDING IN WHICH TO CHALLENGE THE CONSTITUTIONALITY OF A STATUTE.

The Second Department determined petitioner’s application to add more handguns to his pistol permit was properly denied based upon his criminal history, despite the dismissal of most of the charges. The court noted that the Article 78 proceeding was not the proper venue for attacking the constitutionality of the licensing scheme. That should be done in a declaratory judgment action:

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… [G]ood cause existed, based on the petitioner’s criminal history, to deny the petitioner’s application to amend his license to include additional handguns was not arbitrary and capricious, and should not be disturbed… . The fact that the majority of the petitioner’s arrests resulted in the dismissal of the charges against him, or were ultimately resolved in his favor, did not preclude the respondent from considering the underlying circumstances surrounding those arrests in denying the application … .

Moreover, the petitioner’s constitutional challenge to the licensing scheme is unfounded … . We further note that the petitioner’s contention that certain aspects of the licensing eligibility requirements of Penal Law § 400.00(1) unconstitutionally infringe upon his right to bear arms under the Second Amendment (US Const, 2d Amend) is not properly before this Court in an original proceeding pursuant to CPLR article 78, as a declaratory judgment action is the proper vehicle for challenging the constitutionality of a statute … . Matter of Jackson v Anderson, 2017 NY Slip Op 02985, 2nd Dept 4-19-17

 

PISTOL PERMITS (APPLICATION TO ADD HANDGUNS TO PISTOL PERMIT PROPERLY DENIED BASED UPON PETITIONER’S CRIMINAL HISTORY, DECLARATORY JUDGMENT ACTION IS THE PROPER PROCEEDING IN WHICH TO CHALLENGE THE CONSTITUTIONALITY OF A STATUTE)/CIVIL PROCEDURE  (APPLICATION TO ADD HANDGUNS TO PISTOL PERMIT PROPERLY DENIED BASED UPON PETITIONER’S CRIMINAL HISTORY, DECLARATORY JUDGMENT ACTION IS THE PROPER PROCEEDING IN WHICH TO CHALLENGE THE CONSTITUTIONALITY OF A STATUTE)/DECLARATORY JUDGMENT  (APPLICATION TO ADD HANDGUNS TO PISTOL PERMIT PROPERLY DENIED BASED UPON PETITIONER’S CRIMINAL HISTORY, DECLARATORY JUDGMENT ACTION IS THE PROPER PROCEEDING IN WHICH TO CHALLENGE THE CONSTITUTIONALITY OF A STATUTE)

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SMALL CLAIMS ASSESSMENT REVIEW (SCAR) CRITERIA EXPLAINED.

The Second Department determined the small claims assessment review (SCAR) of the tax assessments for petitioners’ properties was proper. The court explained the nature of the SCAR proceeding and the criteria for a court review of a SCAR ruling:

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“The Real Property Tax Law provides that hearings held pursuant to the Small Claims Assessment Review procedure are to be conducted on an informal basis, and the hearing officer is vested with the discretion to consider a wide variety of sources and information, including comparable recent sales, in evaluating tax assessments”… . “The hearing officer shall consider the best evidence presented in each particular case” (RPTL 732[2]), and the hearing officer is required to “determine all questions of fact and law de novo” (RPTL 732[4]). “The decision of the hearing officer shall state the findings of fact and the evidence upon which it is based” (RPTL 733[4]).

“Once a homeowner opts to commence a SCAR proceeding, that property owner waives his or her right to commence a tax review proceeding in Supreme Court under RPTL article 7, title 1, and court review of a JHO’s determination is limited to commencement of a proceeding pursuant to CPLR article 78″…. Accordingly, “[w]hen a hearing officer’s determination is contested, the court’s role is limited to ascertaining whether that determination has a rational basis, that is, whether it is not affected by an error of law or not arbitrary and capricious” … . Matter of Klein v Department of Assessment, 2017 NY Slip Op 02988, 2nd Dept 4-19-17

 

REAL PROPERTY TAX LAW (SMALL CLAIMS ASSESSMENT REVIEW (SCAR) CRITERIA EXPLAINED)/TAX (REAL PROPERTY, SMALL CLAIMS ASSESSMENT REVIEW (SCAR) CRITERIA EXPLAINED)/ASSESSMENTS (REAL PROPERTY TAX LAW, SMALL CLAIMS ASSESSMENT REVIEW (SCAR) CRITERIA EXPLAINED)/SMALL CLAIMS ASSESSMENT REVIEW (SCAR) (REAL PROPERTY TAX LAW, SMALL CLAIMS ASSESSMENT REVIEW (SCAR) CRITERIA EXPLAINED)

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NOTICE OF CLAIM CANNOT BE AMENDED BY ADDING A NEW INJURY AND THEORY OF LIABILITY.

The Second Department determined the plaintiff’s motion to amend the notice of claim against the NYC Health and Hospitals Corporation was properly denied. A notice of claim cannot be amended by adding a new injury theory of liability:

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A notice of claim may be amended only to correct good faith and nonprejudicial technical mistakes, omissions, or defects, not to substantively change the nature of the claim or the theory of liability … . Here, the proposed amendments to the notice of claim asserted a new injury and added a new theory of liability … . These amendments were not technical in nature and are not permitted as late-filed amendments to a notice of claim under General Municipal Law § 50-e(6) … . Castillo v Kings County Hosp. Ctr., 2017 NY Slip Op 02962, 2nd Dept 4-19-17

NEGLIGENCE (NOTICE OF CLAIM CANNOT BE AMENDED BY ADDING A NEW INJURY AND THEORY OF LIABILITY)/MEDICAL MALPRACTICE (NOTICE OF CLAIM CANNOT BE AMENDED BY ADDING A NEW INJURY AND THEORY OF LIABILITY)/MUNICIPAL LAW (NOTICE OF CLAIM CANNOT BE AMENDED BY ADDING A NEW INJURY AND THEORY OF LIABILITY)

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DEFENDANT ABUTTING LESSEE DID NOT AFFIRMATIVELY DEMONSTRATE ITS SNOW REMOVAL EFFORTS DID NOT EXACERBATE THE ICE-SNOW CONDITION IN THIS SIDEWALK SLIP AND FALL CASE, SUMMARY JUDGMENT PROPERLY DENIED.

The Second Department determined defendant (Chase) was not entitled to summary judgment in this abutting sidewalk slip and fall case. Although there was no statute or ordinance which imposed tort liability for failure to remove ice and snow on Chase as the abutting lessee, Chase did not affirmatively demonstrate that it did not exacerbate the ice-snow condition with its snow removal efforts:

The defendant J.P. Morgan Chase Bank, N.A. (hereinafter Chase), leased from [the owner] that portion of the building abutting the sidewalk. Under the terms of the lease and riders in effect at the relevant time, Chase was required to, inter alia, keep the sidewalks and curb in front of its premises clean and free from ice and snow. * * *

Administrative Code of the City of New York § 7-210 imposes a nondelegable duty on a property owner to maintain and repair the sidewalk abutting its property, and specifically imposes liability upon certain property owners for injuries resulting from a violation of the code provision … . In slip-and-fall cases on snow or ice, the general rule is that ” [t]he owner or lessee of property abutting a public sidewalk is under no duty to remove ice and snow that naturally accumulates upon the sidewalk unless a statute or ordinance specifically imposes tort liability for failing to do so'” … . “In the absence of a statute or ordinance imposing tort liability on the lessee, it can be held liable only if it, or someone on its behalf, undertook snow and ice removal efforts which made the naturally-occurring conditions more hazardous” …

Here, there was no statute or ordinance which imposed tort liability on Chase for the failure to maintain the sidewalk abutting its leased portion of the premises. However, Chase failed to make a prima facie showing that it was free from negligence. Chase failed to eliminate triable issues of fact as to whether it undertook snow and ice removal efforts to clear the sidewalk on the date of the subject accident, or whether any snow and ice removal efforts undertaken by it created or exacerbated the icy condition which allegedly caused the plaintiff to fall … . Ramjohn v Yahoo Green, LLC. 2017 NY Slip Op 03028, 2nd Dept 4-19-17

NEGLIGENCE (DEFENDANT ABUTTING LESSEE DID NOT AFFIRMATIVELY DEMONSTRATE ITS SNOW REMOVAL EFFORTS DID NOT EXACERBATE THE ICE-SNOW CONDITION IN THIS SIDEWALK SLIP AND FALL CASE, SUMMARY JUDGMENT PROPERLY DENIED)/LANDLORD-TENANT (SIDEWALK SLIP AND FALL, DEFENDANT ABUTTING LESSEE DID NOT AFFIRMATIVELY DEMONSTRATE ITS SNOW REMOVAL EFFORTS DID NOT EXACERBATE THE ICE-SNOW CONDITION IN THIS SIDEWALK SLIP AND FALL CASE, SUMMARY JUDGMENT PROPERLY DENIED)/SLIP AND FALL (DEFENDANT ABUTTING LESSEE DID NOT AFFIRMATIVELY DEMONSTRATE ITS SNOW REMOVAL EFFORTS DID NOT EXACERBATE THE ICE-SNOW CONDITION IN THIS SIDEWALK SLIP AND FALL CASE, SUMMARY JUDGMENT PROPERLY DENIED)/SIDEWALKS (SLIP AND FALL, DEFENDANT ABUTTING LESSEE DID NOT AFFIRMATIVELY DEMONSTRATE ITS SNOW REMOVAL EFFORTS DID NOT EXACERBATE THE ICE-SNOW CONDITION IN THIS SIDEWALK SLIP AND FALL CASE, SUMMARY JUDGMENT PROPERLY DENIED)

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AUTO REPAIR SHOP OWED NO DUTY TO PLAINTIFF WHO HAD BORROWED THE CAR WHICH HAD BEEN REPAIRED FOR THE OWNER, SINCE NO ESPINAL FACTORS WERE ALLEGED DEFENDANT REPAIR SHOP DID NOT NEED TO NEGATE THOSE FACOTRS IN ITS MOTION FOR SUMMARY JUDGMENT.

The Second Department, reversing Supreme Court, determined defendant auto repair shop (Auto Excellence) did not owe a duty to plaintiff who was injured driving a borrowed car. Plaintiff, who alleged the car was negligently repaired (causing injury), did not have a contractual relationship with the repair shop and did not allege any Espinal factors which could give rise to tort liability based on a contract. Because no Espinal factors were alleged there was no need for defendant to negate those factors in its motion papers:

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A contractual obligation, standing alone, generally will not give rise to tort liability in favor of a third party … , the Court of Appeals recognized that exceptions to this rule apply (1) where the contracting party, in failing to exercise reasonable care in the performance of his or her duties, launches a force or instrument of harm, (2) where the plaintiff detrimentally relies on the continued performance of the contracting party’s duties, and (3) where the contracting party has entirely displaced another party’s duty, in Espinal, to maintain the premises safely.

Here, Auto Excellence made a prima facie showing of its entitlement to judgment as a matter of law by offering proof that the plaintiff was not a party to the repair contract and, thus, Auto Excellence owed her no duty of care … . Contrary to the plaintiff’s contention, since the pleadings did not allege facts which would establish the applicability of any of the Espinal exceptions, Auto Excellence was not required to affirmatively demonstrate that these exceptions did not apply in order to establish its prima facie entitlement to judgment as a matter of law … . Koslosky v Malmut, 2017 NY Slip Op 02977, 2nd Dept 4-19-17

NEGLIGENCE (AUTO REPAIR SHOP OWED NO DUTY TO PLAINTIFF WHO HAD BORROWED THE CAR WHICH HAD BEEN REPAIRED BY THE OWNER, SINCE NO ESPINAL FACTORS WERE ALLEGED DEFENDANT REPAIR SHOP DID NOT NEED TO NEGATE THOSE FACTORS IN ITS MOTION FOR SUMMARY JUDGMENT)/CONTRACT LAW (TORT LIABILITY TO THIRD PARTY, (AUTO REPAIR SHOP OWED NO DUTY TO PLAINTIFF WHO HAD BORROWED THE CAR WHICH HAD BEEN REPAIRED BY THE OWNER, SINCE NO ESPINAL FACTORS WERE ALLEGED DEFENDANT REPAIR SHOP DID NOT NEED TO NEGATE THOSE FACTORS IN ITS MOTION FOR SUMMARY JUDGMENT)/CIVIL PROCEDURE (ESPINAL FACTORS, (AUTO REPAIR SHOP OWED NO DUTY TO PLAINTIFF WHO HAD BORROWED THE CAR WHICH HAD BEEN REPAIRED BY THE OWNER, SINCE NO ESPINAL FACTORS WERE ALLEGED DEFENDANT REPAIR SHOP DID NOT NEED TO NEGATE THOSE FACTORS IN ITS MOTION FOR SUMMARY JUDGMENT)

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FIVE INCH HIGH THRESHOLD WAS OPEN AND OBVIOUS AND NOT INHERENTLY DANGEROUS, NO EVIDENCE BUILDING BUILT IN 1924 MUST BE BROUGHT UP TO CODE OR COMPLY WITH THE AMERICANS WITH DISABILITIES ACT.

The Second Department determined the plaintiff did not demonstrate the property owner’s failure to modify a five-inch high threshold in a brightly lit area created a dangerous condition. The building was constructed in 1924 and there was no showing the owner was required to bring the building up to code or to comply with the Americans with Disabilities Act. The court noted that the standards promulgated by the American Society for Testing and Materials were not  mandatory and could not be the basis for liability:

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… [The owner and property manager] demonstrated their prima facie entitlement to judgment as a matter of law by submitting evidence that the threshold to the entrance of the premises was approximately five inches high and located in a brightly lit area, and therefore open and obvious and not inherently dangerous … . In opposition, the plaintiff failed to raise a triable issue of fact as to whether the defect was actionable … . In his affidavit, the plaintiff’s expert architect did not dispute the fact that the premises were constructed in 1924, prior to the enactment of the building code, and cited no requirement that the premises be renovated to meet the building code enacted subsequent to its construction. Further, the Americans With Disabilities Act … standards, relied upon by the plaintiff’s expert, generally do not require renovation of buildings constructed prior to 1991 … , and the expert cited no evidence that any exceptions to that rule were applicable here. The expert’s reliance on standards promulgated by the American Society for Testing and Materials did not raise a triable issue of fact as to the liability of [the owner and property manager], since those standards are nonmandatory guidelines, a violation of which would not support a finding of liability … . Futter v Hewlett Sta. Yogurt, Inc., 2017 NY Slip Op 02970, 2nd Dept 4-19-17

NEGLIGENCE (FIVE INCH HIGH THRESHOLD WAS OPEN AND OBVIOUS AND NOT INHERENTLY DANGEROUS, NO EVIDENCE BUILDING BUILT IN 1924 MUST BE BROUGHT UP TO CODE OR COMPLY WITH THE AMERICANS WITH DISABILITIES ACT)/PREMISES LIABILITY (FIVE INCH HIGH THRESHOLD WAS OPEN AND OBVIOUS AND NOT INHERENTLY DANGEROUS, NO EVIDENCE BUILDING BUILT IN 1924 MUST BE BROUGHT UP TO CODE OR COMPLY WITH THE AMERICANS WITH DISABILITIES ACT)/SLIP AND FALL (FIVE INCH HIGH THRESHOLD WAS OPEN AND OBVIOUS AND NOT INHERENTLY DANGEROUS, NO EVIDENCE BUILDING BUILT IN 1924 MUST BE BROUGHT UP TO CODE OR COMPLY WITH THE AMERICANS WITH DISABILITIES ACT)/AMERICANS WITH DISABILITIES ACT (PREMISES LIABILITY, FIVE INCH HIGH THRESHOLD WAS OPEN AND OBVIOUS AND NOT INHERENTLY DANGEROUS, NO EVIDENCE BUILDING BUILT IN 1924 MUST BE BROUGHT UP TO CODE OR COMPLY WITH THE AMERICANS WITH DISABILITIES ACT)/OPEN AND OBVIOUS (PREMISES LIABILITY, FIVE INCH HIGH THRESHOLD WAS OPEN AND OBVIOUS AND NOT INHERENTLY DANGEROUS, NO EVIDENCE BUILDING BUILT IN 1924 MUST BE BROUGHT UP TO CODE OR COMPLY WITH THE AMERICANS WITH DISABILITIES ACT)

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