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LEAVE TO FILE A LATE NOTICE OF CLAIM SHOULD NOT HAVE BEEN GRANTED.

The First Department, over a two-justice dissent, determined Supreme Court should not have granted leave to file a late notice of claim. “Petitioner was injured on July 15, 2015, while working as a bricklayer … at a job site located at an intermediate school in the Bronx. Petitioner alleges that while lifting 60 to 70 pound buckets, he tripped and fell due to an uneven floor on a makeshift scaffold. He filed a workers’ compensation claim on July 29, 2015, but did not file a notice of claim until July 15, 2016, a year later. In the intervening year, he underwent a shoulder and a hip surgery:”

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The motion court improvidently exercised its discretion in granting the motion. Petitioner failed to establish any of the relevant statutory factors that would warrant leave to serve a late notice of claim … . Petitioner’s alleged failure to realize the severity of his injuries within 90 days after his accident did not constitute a reasonable excuse for his delay in serving a notice of claim, especially since petitioner filed a workers’ compensation claim just weeks after the accident… . Nor did petitioner show that respondents acquired actual knowledge of the essential facts constituting the claim within the statutory period, or a reasonable time thereafter (see General Municipal Law § 50-e[5]). There is no evidence that respondents received petitioner’s workers’ compensation claim form, which, in any event, makes no mention of the allegations against respondents … . Absent any knowledge of even a potential Labor Law claim, respondents certainly had no basis to conduct their own investigations … .

* * * … [T]here is no evidence respondents were aware of an accident even occurring. Petitioner … does no more than refer to numerous construction records that purportedly could be examined, yet provides no names of actual witnesses nor any reference to specific information in those records. Matter of Grajko v City of New York, 2017 NY Slip Op 04203, 1st Dept 5-24-17

 

MUNICIPAL LAW (LEAVE TO FILE A LATE NOTICE OF CLAIM SHOULD NOT HAVE BEEN GRANTED)/NEGLIGENCE (MUNICIPAL LAW, NOTICE OF CLAIM, LEAVE TO FILE A LATE NOTICE OF CLAIM SHOULD NOT HAVE BEEN GRANTED)/NOTICE OF CLAIM (MUNICIPAL LAW, LEAVE TO FILE A LATE NOTICE OF CLAIM SHOULD NOT HAVE BEEN GRANTED)

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WATER DISTRICT’S CONSTRUCTION OF A REPLACEMENT DRINKING WATER SUPPLY TANK WAS IMMUNE FROM COMPLIANCE WITH THE VILLAGE CODE AND DID NOT TRIGGER THE STATE ENVIRONMENTAL QUALITY REVIEW ACT.

The Second Department determined Supreme Court properly concluded the Water District’s planned replacement of a drinking water supply tank was immune from the village code and did not trigger the State Environmental Quality Review Act (SEQRA):

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In Matter of County of Monroe (City of Rochester) (72 NY2d 338), the Court of Appeals addressed the applicability of local zoning laws where a conflict exists between two governmental entities. The Court therein articulated “a balancing of public interests” test which requires the consideration of various factors in order to determine whether an entity should be granted immunity from local zoning requirements … . These factors include “the nature and scope of the instrumentality seeking immunity, the kind of function or land use involved, the extent of the public interest to be served thereby, the effect local land use regulation would have upon the enterprise concerned and the impact upon legitimate local interests” … .

Here, the Village failed to set forth any basis for its contention that the application of the Monroe balancing test is in the exclusive province of the Village, or host entity. In fact, the Court of Appeals did not specify the entity initially responsible for evaluating the competing interests … . Further, the Supreme Court properly employed the “balancing of public interests” test and correctly determined that the proposed construction plan is immune from the Village’s local laws … .

The Supreme Court also properly found, in effect, that the Water District’s determination that the proposed construction plan was for a “replacement, rehabilitation or reconstruction of a structure or facility, in kind” (6 NYCRR 617.5[c][2]) and, thus, was a Type II action under SEQRA that presumptively did not have a significant impact upon the environment and did not require the preparation and circulation of an environmental impact statement, was not irrational, arbitrary or capricious, affected by error of law, or an abuse of discretion … . Incorporated Vil. of Munsey Park v Manhasset-Lakeville Water Dist., 2017 NY Slip Op 03934, 2nd Dept 5-17-17

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ZONING (WATER DISTRICT’S CONSTRUCTION OF A REPLACEMENT DRINKING WATER SUPPLY TANK WAS IMMUNE FROM COMPLIANCE WITH THE VILLAGE CODE AND DID NOT TRIGGER THE STATE ENVIRONMENTAL QUALITY REVIEW ACT)/ENVIRONMENTAL LAW (REPLACEMENT WATER TANK, WATER DISTRICT’S CONSTRUCTION OF A REPLACEMENT DRINKING WATER SUPPLY TANK WAS IMMUNE FROM COMPLIANCE WITH THE VILLAGE CODE AND DID NOT TRIGGER THE STATE ENVIRONMENTAL QUALITY REVIEW ACT)/MONROE BALANCING TEST (REPLACEMENT WATER TANK, WATER DISTRICT’S CONSTRUCTION OF A REPLACEMENT DRINKING WATER SUPPLY TANK WAS IMMUNE FROM COMPLIANCE WITH THE VILLAGE CODE AND DID NOT TRIGGER THE STATE ENVIRONMENTAL QUALITY REVIEW ACT)/STATE ENVIRONMENTAL QUALITY REVIEW ACT (SEQRA)  (REPLACEMENT WATER TANK, WATER DISTRICT’S CONSTRUCTION OF A REPLACEMENT DRINKING WATER SUPPLY TANK WAS IMMUNE FROM COMPLIANCE WITH THE VILLAGE CODE AND DID NOT TRIGGER THE STATE ENVIRONMENTAL QUALITY REVIEW ACT)/WATER TANKS (WATER DISTRICT’S CONSTRUCTION OF A REPLACEMENT DRINKING WATER SUPPLY TANK WAS IMMUNE FROM COMPLIANCE WITH THE VILLAGE CODE AND DID NOT TRIGGER THE STATE ENVIRONMENTAL QUALITY REVIEW ACT)/MUNICIPAL LAW  (WATER DISTRICT’S CONSTRUCTION OF A REPLACEMENT DRINKING WATER SUPPLY TANK WAS IMMUNE FROM COMPLIANCE WITH THE VILLAGE CODE AND DID NOT TRIGGER THE STATE ENVIRONMENTAL QUALITY REVIEW ACT)

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MOTION FOR LEAVE TO AMEND NOTICE OF CLAIM TO INDICATE PLAINTIFF WAS RIDING A BICYCLE AT THE TIME OF THE ACCIDENT PROPERLY GRANTED.

The Second Department determined plaintiff’s motion for leave to amend the notice of claim was properly granted in this bicycle accident case. The notice of claim stated plaintiff was “lawfully traveling” on a service road when injured by a defect in the road. The amendment sought to indicate plaintiff was riding a bicycle at the time he was injured:

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A court may, in its discretion, grant an application for leave to serve an amended notice of claim if the mistake, omission, irregularity, or defect in the original notice was made in good faith, and the municipality has not been prejudiced … . In making a determination as to whether the municipality has been prejudiced, the court may consider the evidence adduced at a hearing conducted pursuant to General Municipal Law § 50-h, as well as any other evidence that is properly before the court … .

Here, the record does not show any bad faith on the part of the plaintiff, and the County failed to show that it would be prejudiced by the amendment. In particular, the County does not allege that the condition of the roadway changed prior to the service of the summons and complaint, which alleged that the plaintiff was injured while bicycling. Moreover, the record shows that Nassau County Police Department EMS personnel responded to the scene of the accident, and EMS personnel prepared a written report indicating that the plaintiff fell from a bicycle. Fast v County of Nassau, 2017 NY Slip Op 03734, 2nd Dept 5-10-17

 

MUNICIPAL LAW (MOTION FOR LEAVE TO AMEND NOTICE OF CLAIM TO INDICATE PLAINTIFF WAS RIDING A BICYCLE AT THE TIME OF THE ACCIDENT PROPERLY GRANTED)/NEGLIGENCE (MUNICIPAL LAW, MOTION FOR LEAVE TO AMEND NOTICE OF CLAIM TO INDICATE PLAINTIFF WAS RIDING A BICYCLE AT THE TIME OF THE ACCIDENT PROPERLY GRANTED)/NOTICE OF CLAIM (MOTION FOR LEAVE TO AMEND NOTICE OF CLAIM TO INDICATE PLAINTIFF WAS RIDING A BICYCLE AT THE TIME OF THE ACCIDENT PROPERLY GRANTED)

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PLAINTIFF STATED A CAUSE OF ACTION AGAINST THE COUNTY UNDER 42 USC 1983 FOR VIOLATION OF HIS RIGHT TO A SPEEDY TRIAL.

The Second Department, reversing Supreme Court, determined plaintiff had stated a cause of action under 18 USC 1983, against the county, for violation of his right to a speedy trial:

We reject the County’s argument that it cannot be held liable pursuant to 42 USC § 1983 for the alleged misconduct of the office of the District Attorney. Where, as here, a complaint alleges a failure to train and supervise employees regarding legal obligations, “liability for the District Attorney’s actions in his role as a manager of the District Attorney’s office rests with the county” …  and a claim pursuant to 42 USC § 1983 may therefore be maintained against the County for the conduct of the District Attorney’s office insofar as the District Attorney acted as a County policymaker … . Moreover, here, the complaint sufficiently alleges that the District Attorney’s office failed to train and supervise its assistant district attorneys with respect to the constitutional speedy trial rights of the accused persons with whom they interacted, to the extent that they manifested deliberate indifference to those rights … . Victor v County of Suffolk, 2017 NY Slip Op 03796, 2nd Dept 5-10-17

CRIMINAL LAW (PLAINTIFF STATED A CAUSE OF ACTION AGAINST THE COUNTY UNDER 18 USC 1983 FOR VIOLATION OF HIS RIGHT TO A SPEEDY TRIAL)/CIVIL RIGHTS LAW (18 USC 1983) (SPEEDY TRIAL, PLAINTIFF STATED A CAUSE OF ACTION AGAINST THE COUNTY UNDER 18 USC 1983 FOR VIOLATION OF HIS RIGHT TO A SPEEDY TRIAL)/MUNICIPAL LAW (SPEEDY TRIAL, PLAINTIFF STATED A CAUSE OF ACTION AGAINST THE COUNTY UNDER 18 USC 1983 FOR VIOLATION OF HIS RIGHT TO A SPEEDY TRIAL)/SPEEDY TRIAL (CIVIL RIGHTS VIOLATION, PLAINTIFF STATED A CAUSE OF ACTION AGAINST THE COUNTY UNDER 18 USC 1983 FOR VIOLATION OF HIS RIGHT TO A SPEEDY TRIAL)

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STATE TROOPER IMMUNE FROM A PERSONAL INJURY SUIT BASED UPON THE TROOPER’S DISCRETIONARY ACTS.

The Third Department, reversing (modifying) Supreme Court, determined a state trooper, defendant Begeal, was entitled to summary judgment in this personal injury case because he was immune from suit for his actions, which were discretionary. Plaintiff physician assistant was injured by a patient (Lacey) brought into the hospital by law enforcement officers, including Begeal. Plaintiff was kicked by the patient and alleged Begeal negligently failed to restrain the patient’s legs:

Although Begeal had access to plastic leg restraints, the undisputed evidence established that, at the time that he left the examination room, Lacey was still handcuffed, was “extremely calm” and had allowed a nurse to remove pieces of glass from his feet without kicking or otherwise resisting the nurse’s efforts. Begeal thus made a “reasoned judgment” not to utilize the leg restraints … . Accordingly, “[t]he decision to employ [only handcuffs] was a discretionary one . . ., and [Begeal] may not be held liable for that determination” … . …

Begeal’s decision to leave the examination room to permit the medical personnel to examine Lacey in private was likewise discretionary. Although Lacey was combative when he first arrived at the hospital, Begeal did not leave the examination room until approximately 20 minutes after that time and only after ensuring that Lacey had calmed down. Based on these circumstances, Begeal “did not feel that [the hospital personnel and Feeney] were in any immediate danger” and concluded that he could safely leave the room and go to the main area in order to, among other things, wash off Lacey’s blood from his clothes. While Begeal’s judgment call proved to be incorrect, “it is not for courts to second-guess the wisdom of discretionary governmental choices, troubling though they may sometimes seem in the glaring clarity of hindsight” … . Feeney v County of Del., 2017 NY Slip Op 03583, 3rd Dept 5-4-17

 

NEGLIGENCE (STATE TROOPER IMMUNE FROM A PERSONAL INJURY SUIT BASED UPON THE TROOPER’S DISCRETIONARY ACTS)/MUNICIPAL LAW (IMMUNITY, STATE TROOPER IMMUNE FROM A PERSONAL INJURY SUIT BASED UPON THE TROOPER’S DISCRETIONARY ACTS)/IMMUNITY (STATE TROOPER IMMUNE FROM A PERSONAL INJURY SUIT BASED UPON THE TROOPER’S DISCRETIONARY ACTS)/GOVERNMENTAL IMMUNITY (STATE TROOPER IMMUNE FROM A PERSONAL INJURY SUIT BASED UPON THE TROOPER’S DISCRETIONARY ACTS)

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NOTICE OF CLAIM WHICH WAS MISDIRECTED BECAUSE OF A MINOR MISNOMER ON THE MAILED ENVELOPE DEEMED TIMELY SERVED.

The Second Department, over a dissent, reversing Supreme Court, determined that a notice of claim which named the correct party (New York City Housing Authority [NYCHA]) and address but mistakenly indicated the “Comptroller” of the NYCHA on the mailed envelope, was properly served. The envelope was misdirected to the Comptroller of the City of New York, despite the fact that the comptroller is at an entirely different address than that on the envelope:

As pertinent to this appeal, General Municipal Law § 50-e(3)(a) provides that the notice of claim should be mailed “to the person designated by law as one to whom a summons in an action . . . may be delivered.” Although the statute requires that the notice be mailed to the designated “person,” this generally refers to the public authority or government entity itself rather than a particular person employed thereby … . Here, there is no real dispute that simply writing “NYCHA” on the envelope would have satisfied the requirements of the statute.

Further, while NYCHA contends that there is no such person or entity as the “Comptroller of the NYCHA,” a “comptroller” is simply an officer of a municipal corporation, like NYCHA, “who is charged with duties [usually] relating to fiscal affairs, including auditing and examining accounts and reporting the financial status periodically” (Black’s Law Dictionary 347 [10th ed 2014]). In any event, the minor misnomer on the envelope need not be fatal to the action, especially where, as here, the plaintiff’s attorney properly mailed the same notice of claim form to both the Comptroller and NYCHA in order to assert a claim against both the City of New York and NYCHA, and the notice of claim itself named NYCHA.

Under these circumstances, we find that the envelope was properly addressed within the meaning of General Municipal Law § 50-e(3)(b) and the plaintiff properly served the notice of claim upon NYCHA within the requisite 90-day statutory period … . Carroll v City of New York. 2017 NY Slip Op 03148, 2nd Dept 4-26-2017

MUNICIPAL LAW (NOTICE OF CLAIM WHICH WAS MISDIRECTED BECAUSE OF A MINOR MISNOMER ON THE MAILED ENVELOPE DEEMED TIMELY SERVED)/NEGLIGENCE (MUNICIPAL LAW, NOTICE OF CLAIM WHICH WAS MISDIRECTED BECAUSE OF A MINOR MISNOMER ON THE MAILED ENVELOPE DEEMED TIMELY SERVED)/NOTICE OF CLAIM (MUNICIPAL LAW, NOTICE OF CLAIM WHICH WAS MISDIRECTED BECAUSE OF A MINOR MISNOMER ON THE MAILED ENVELOPE DEEMED TIMELY SERVED)

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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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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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LATE NOTICE OF CLAIM PROPERLY DENIED, POSSESSION OF DECEDENT’S HOSPITAL RECORDS NOT ENOUGH TO DEMONSTRATE HOSPITAL’S TIMELY AWARENESS OF THE POTENTIAL CLAIM FOR CONSCIOUS PAIN AND SUFFERING.

The Second Department determined a petition for leave to file a late notice of claim against the NYC Health and Hospitals Corporation for conscious pain and suffering was properly denied. The court determined the hospital was not timely put on notice of the claim simply by its possession of the decedent’s hospital records:

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Contrary to the petitioner’s contention, the respondent did not acquire actual knowledge of the essential facts constituting the claim to recover damages for conscious pain and suffering within the requisite 90-day period or a reasonable time thereafter by virtue of its possession of hospital records relating to the decedent’s death … . A medical provider’s mere possession or creation of medical records does not establish that it had “actual knowledge of a potential injury where the records do not evince that the medical staff, by its acts or omissions, inflicted any injury on” the claimant … . Furthermore, the petitioner failed to demonstrate a reasonable excuse for the failure to serve a timely notice of claim and for the lengthy delay in filing the petition … . Even assuming that the petitioner met its initial burden to show that the late notice will not substantially prejudice the respondent, and that the respondent failed to make “a particularized evidentiary showing that [it] will be substantially prejudiced if the late notice is allowed” in response … , upon consideration of the balance of the relevant factors (see General Municipal Law § 50-e[5]), the Supreme Court providently exercised its discretion in denying leave to serve a late notice of claim with respect to the cause of action alleging conscious pain and suffering … . Matter of Rosenblatt v New York City Health & Hosps. Corp., 2017 NY Slip Op 03004. 1st Dept 4-19-17

MUNICIPAL LAW (LATE NOTICE OF CLAIM PROPERLY DENIED, POSSESSION OF DECEDENT’S HOSPITAL RECORDS NOT ENOUGH TO DEMONSTRATE HOSPITAL’S TIMELY AWARENESS OF THE POTENTIAL CLAIM)/NOTICE OF CLAIM (MUNICIPAL LAW, LATE NOTICE OF CLAIM PROPERLY DENIED, POSSESSION OF DECEDENT’S HOSPITAL RECORDS NOT ENOUGH TO DEMONSTRATE HOSPITAL’S TIMELY AWARENESS OF THE POTENTIAL CLAIM)/NEGLIGENCE (MUNICIPAL LAW, LATE NOTICE OF CLAIM PROPERLY DENIED, POSSESSION OF DECEDENT’S HOSPITAL RECORDS NOT ENOUGH TO DEMONSTRATE HOSPITAL’S TIMELY AWARENESS OF THE POTENTIAL CLAIM)

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DIFFERENCES BETWEEN CONTRIBUTION AND INDEMNIFICATION EXPLAINED, PERSONAL TORT LIABILITY OF CORPORATE OFFICERS NOTED.

The Second Department, in a lawsuit stemming from the flooding of plaintiffs’ land, explained the differences between contribution and indemnification and noted that corporate officers may be personally liable for torts committed in their performance of corporate duties:

The plaintiffs commenced this action against the Village of East Hills after they experienced flooding on their property from rainwater. The plaintiffs asserted causes of action sounding in tort, alleging that the flooding resulted from the development of land near their property, which was authorized by the Village. The Village commenced a third-party action seeking indemnification and contribution against A to Z Transit Contracting Corp., the project manager that constructed the plaintiffs’ home, as well as its principal, David Ferdinand, architect Carl Majowka, who prepared plans for the construction of the plaintiffs’ home, and Scott Anderson, the principal of Scott Anderson Design, Inc., which performed landscaping work for the plaintiffs’ home. * * *

“[C]ontribution arises automatically when certain factors are present and [does] not requir[e] any kind of agreement between or among the wrongdoers'” … . ” Indemnity, on the other hand, arises out of a contract which may be express or may be implied in law “to prevent a result which is regarded as unjust or unsatisfactory”‘” … . “Further, “[w]here one is held liable solely on account of the negligence of another, indemnification, not contribution, principles apply to shift the entire liability to the one who was negligent.” . . . Conversely, where a party is held liable at least partially because of its own negligence, contribution against other culpable tort-feasors is the only available remedy'”… . “Whether indemnity or contribution applies depends not upon the parties’ designation but upon a careful analysis of the theory of recovery against each tort-feasor'”       * * *

Although “[c]orporate officers may not be held personally liable on contracts of their corporations, provided they did not purport to bind themselves individually under such contracts” … , “corporate officers may be held personally liable for torts committed in the performance of their corporate duties'” … . Eisman v Village of E. Hills. 2017 NY Slip Op 02775, 2nd Dept 4-12-17

NEGLIGENCE (DIFFERENCES BETWEEN CONTRIBUTION AND INDEMNIFICATION EXPLAINED, PERSONAL TORT LIABILITY OF CORPORATE OFFICERS NOTED)/CONTRACT LAW (DIFFERENCES BETWEEN CONTRIBUTION AND INDEMNIFICATION EXPLAINED, PERSONAL TORT LIABILITY OF CORPORATE OFFICERS NOTED)/CORPORATION LAW  (DIFFERENCES BETWEEN CONTRIBUTION AND INDEMNIFICATION EXPLAINED, PERSONAL TORT LIABILITY OF CORPORATE OFFICERS NOTED)/MUNICIPAL LAW (DIFFERENCES BETWEEN CONTRIBUTION AND INDEMNIFICATION EXPLAINED, PERSONAL TORT LIABILITY OF CORPORATE OFFICERS NOTED)

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