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PLAINTIFF’S INABILITY TO PINPOINT THE CAUSE OF HIS FALL FROM A LADDER DID NOT WARRANT SUMMARY JUDGMENT, THERE WAS CIRCUMSTANTIAL EVIDENCE OF THE CAUSE.

The First Department determined plaintiff’s inability to state exactly how the accident happened did not warrant summary judgment. Circumstantial evidence established that the bottom of plaintiff’s ladder slid out from under him:

“A plaintiff’s inability to testify exactly as to how an accident occurred does not require dismissal where negligence and causation can be established with circumstantial evidence” … . Plaintiff established his entitlement to partial summary judgment on the Labor Law § 240(1) claim, despite his admitted inability to remember the specifics of the accident, through the submission of a workers’ compensation report and the statement of defendant … , both of which established that the accident occurred when the bottom of the ladder from which plaintiff was descending suddenly slipped out from under him, causing him to fall to the ground … . Weicht v City of New York, 2017 NY Slip Op 01995, 1st Dept 3-21-17

LABOR LAW-CONSTRUCTION LAW (PLAINTIFF’S INABILITY TO PINPOINT THE CAUSE OF HIS FALL FROM A LADDER DID NOT WARRANT SUMMARY JUDGMENT, THERE WAS CIRCUMSTANTIAL EVIDENCE OF THE CAUSE)/EVIDENCE (LABOR LAW-CONSTRUCTION LAW, PLAINTIFF’S INABILITY TO PINPOINT THE CAUSE OF HIS FALL FROM A LADDER DID NOT WARRANT SUMMARY JUDGMENT, THERE WAS CIRCUMSTANTIAL EVIDENCE OF THE CAUSE)/LADDERS (LABOR LAW-CONSTRUCTION LAW, PLAINTIFF’S INABILITY TO PINPOINT THE CAUSE OF HIS FALL FROM A LADDER DID NOT WARRANT SUMMARY JUDGMENT, THERE WAS CIRCUMSTANTIAL EVIDENCE OF THE CAUSE)

FIRST DEPT REDUCED DEFENDANT’S SORA RISK LEVEL FROM THREE TO TWO, BASED PRIMARILY UPON DEFENDANT’S USE OF EDUCATIONAL AND REHABILITATIVE RESOURCES WHILE IN PRISON.

The First Department took the unusual step of reducing defendant’s SORA risk level from three to two. Defendant committed a heinous rape 30 years ago when he was using drugs and alcohol. While in prison defendant earned two bachelor degrees and completed many therapeutic programs:

The Court of Appeals has enunciated a three-step process for determining whether to depart downward from a defendant’s presumptive risk level … . First, a court must decide whether the proffered mitigating circumstance or circumstances are “of a kind, or to a degree, not adequately taken into account by the guidelines” … . Second, a court must determine whether the defendant seeking a downward departure has proven the existence of these alleged mitigating circumstances by a preponderance of the evidence … . If the defendant surmounts these first two steps, a court must then exercise its discretion and determine at the final third step, “whether the totality of the circumstances warrants a departure” …. .

Here, we find that, under this three-step analysis, a departure to level two is warranted. Initially, we note that defendant has met his burden of proving the existence of mitigating circumstances unaccounted for in the Guidelines by a preponderance of the evidence. Defendant’s remarkable rehabilitation and his pain and mobility problems constitute, in this case, the sort of “special circumstances” for which a downward departure is appropriate … . Moreover, defendant supported his application with a number of exhibits, including his degrees, his medical records, and his letters of recommendation. People v Williams, 2017 NY Slip Op 01988, 1st Dept 3-21-17

 

CRIMINAL LAW (FIRST DEPARTMENT REDUCED DEFENDANT’S SORA RISK LEVEL FROM THREE TO TWO, BASED PRIMARILY UPON DEFENDANT’S USE OF EDUCATIONAL AND REHABILITATIVE RESOURCES WHILE IN PRISON)/SEX OFFENDER REGISTRATION ACT (SORA) (FIRST DEPARTMENT REDUCED DEFENDANT’S SORA RISK LEVEL FROM THREE TO TWO, BASED PRIMARILY UPON DEFENDANT’S USE OF EDUCATIONAL AND REHABILITATIVE RESOURCES WHILE IN PRISON)

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TRIVIAL DEFECT IN SIDEWALK NOT ACTIONABLE, DESPITE ABSENCE OF NEGLIGENCE BROAD INDEMNFICATION CLAUSE MANDATED PAYMENT OF DEFENDANT’S COSTS ASSOCIATED WITH THE ACTION.

The First Department determined the sidewalk defect was trivial and not actionable but the costs associated with defending the action were recoverable under the broad language of an indemnification clause (despite the absence of negligence):

Plaintiff’s description of the alleged defect that caused her fall as an “uneven spot” that “wasn’t as level as the other side” of a “little ridge” of concrete in the ground, without more, establishes that the alleged defect was trivial and nonactionable … . Moreover, defendants established that they had no notice of the alleged defect … . …

The indemnification provision in Montesano’s contract was … broad and required Montesano to indemnify defendants for liability, damage, etc., “resulting from, arising out of or occurring in connection with the execution of the Work,” including attorneys’ fees. Thus, although there was no negligence here, to the extent defendants incurred costs connected with Montesano’s execution of its work, which included constructing/resurfacing roads and sidewalks on this shopping center renovation project, Montesano is required to indemnify defendants. Robinson v Brooks Shopping Ctrs., LLC, 2017 NY Slip Op 01972 1st Dept 3-16-17

 

NEGLIGENCE (TRIVIAL DEFECT IN SIDEWALK NOT ACTIONABLE, DESPITE ABSENCE OF NEGLIGENCE BROAD INDEMNFICATION CLAUSE MANDATED PAYMENT OF DEFENDANT’S COSTS ASSOCIATED WITH THE ACTION)/CONTRACT LAW (INDEMNFICATION CLAUSE, TRIVIAL DEFECT IN SIDEWALK NOT ACTIONABLE, DESPITE ABSENCE OF NEGLIGENCE BROAD INDEMNFICATION CLAUSE MANDATED PAYMENT OF DEFENDANT’S COSTS ASSOCIATED WITH THE ACTION)/INDEMNIFICATION CLAUSE TRIVIAL DEFECT IN SIDEWALK NOT ACTIONABLE, DESPITE ABSENCE OF NEGLIGENCE BROAD INDEMNFICATION CLAUSE MANDATED PAYMENT OF DEFENDANT’S COSTS ASSOCIATED WITH THE ACTION)/SLIP AND FALL (TRIVIAL DEFECT IN SIDEWALK NOT ACTIONABLE, DESPITE ABSENCE OF NEGLIGENCE BROAD INDEMNFICATION CLAUSE MANDATED PAYMENT OF DEFENDANT’S COSTS ASSOCIATED WITH THE ACTION)/TRIVIAL DEFECT (SLIP AND FALL, TRIVIAL DEFECT IN SIDEWALK NOT ACTIONABLE, DESPITE ABSENCE OF NEGLIGENCE BROAD INDEMNFICATION CLAUSE MANDATED PAYMENT OF DEFENDANT’S COSTS ASSOCIATED WITH THE ACTION)

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ALLOWING POLICE OFFICER TO TESTIFY ABOUT VICTIM’S IDENTIFICATION OF DEFENDANT AT A SHOWUP WAS NOT BOLSTERING, VICTIM’S STATEMENT WAS AN EXCITED UTTERANCE.

The First Department determined a police officer was properly allowed to testify the robbery victim identified defendant at a showup because the victim’s statement was an excited utterance:

At trial, the court properly permitted a police officer to testify that the victim of the … robbery identified defendant at a showup. This testimony was admissible, notwithstanding the general rule against third-party bolstering … , because the victim’s declaration qualified as an excited utterance. Shortly after the victim was robbed at gunpoint in his taxicab, he called 911 and was brought in a police vehicle to defendant, who was being detained. The victim immediately yelled, “[O]h my God[!] . . . [I]t is the same guy . . . . Thank God you caught him[!]” Under the circumstances, this identification was made “under the stress of excitement caused by an external event, and [was] not the product of studied reflection and possible fabrication” … . People v Everette, 2017 NY Slip Op 01962, 1st Dept 3-16-17

CRIMINAL LAW (EVIDENCE, ALLOWING POLICE OFFICER TO TESTIFY ABOUT VICTIM’S IDENTIFICATION OF DEFENDANT AT A SHOWUP WAS NOT BOLSTERING, VICTIM’S STATEMENT WAS AN EXCITED UTTERANCE)/EVIDENCE (CRIMINAL LAW, ALLOWING POLICE OFFICER TO TESTIFY ABOUT VICTIM’S IDENTIFICATION OF DEFENDANT AT A SHOWUP WAS NOT BOLSTERING, VICTIM’S STATEMENT WAS AN EXCITED UTTERANCE)/HEARSAY (CRIMINAL LAW, ALLOWING POLICE OFFICER TO TESTIFY ABOUT VICTIM’S IDENTIFICATION OF DEFENDANT AT A SHOWUP WAS NOT BOLSTERING, VICTIM’S STATEMENT WAS AN EXCITED UTTERANCE)/BOLSTERING (CRIMINAL LAW, ALLOWING POLICE OFFICER TO TESTIFY ABOUT VICTIM’S IDENTIFICATION OF DEFENDANT AT A SHOWUP WAS NOT BOLSTERING, VICTIM’S STATEMENT WAS AN EXCITED UTTERANCE)/EXCITED UTTERANCE (CRIMINAL LAW, ALLOWING POLICE OFFICER TO TESTIFY ABOUT VICTIM’S IDENTIFICATION OF DEFENDANT AT A SHOWUP WAS NOT BOLSTERING, VICTIM’S STATEMENT WAS AN EXCITED UTTERANCE)/SHOWUP IDENTIFICATION CRIMINAL LAW, ALLOWING POLICE OFFICER TO TESTIFY ABOUT VICTIM’S IDENTIFICATION OF DEFENDANT AT A SHOWUP WAS NOT BOLSTERING, VICTIM’S STATEMENT WAS AN EXCITED UTTERANCE)/INDENTIFICATION (CRIMINAL LAW, ALLOWING POLICE OFFICER TO TESTIFY ABOUT VICTIM’S IDENTIFICATION OF DEFENDANT AT A SHOWUP WAS NOT BOLSTERING, VICTIM’S STATEMENT WAS AN EXCITED UTTERANCE)

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NO NEED FOR ARRESTING OFFICER TO TESTIFY AT SUPPRESSION HEARING, INFERENCE OF MUTUAL COMMUNICATION APPLIED.

The First Department determined the arresting officer did not need to testify at the suppression hearing and explained the inference of mutual communication:

The arresting officer had probable cause to arrest defendant under the fellow officer rule because “the radio transmission [of] the undercover officer . . . provided details of the defendant’s race, sex, clothing, as well as his location and the fact that a positive buy’ had occurred” and defendant was the only person in the area who matched the description at the location … . Although the arresting officer did not testify at the suppression hearing, “the only rational explanation for how defendant came to be arrested . . . is that [the arresting officer] heard the radio communication [heard by the testifying officer] and apprehended defendant on that basis” … . The inference of mutual communication … does not turn on what kind of radios the officers were using, or how well the radios were working, but on the simple fact that, without hearing the radio transmission, the arresting officer would have had no way of knowing where to go or whom to arrest. People v Vidro, 2017 NY Slip Op 01975, 1st Dept 3-16-17

CRIMINAL LAW (NO NEED FOR ARRESTING OFFICER TO TESTIFY AT SUPPRESSION HEARING, INFERENCE OF MUTUAL COMMUNICATION APPLIED)/EVIDENCE (CRIMINAL LAW, NO NEED FOR ARRESTING OFFICER TO TESTIFY AT SUPPRESSION HEARING, INFERENCE OF MUTUAL COMMUNICATION APPLIED)/MUTUAL COMMUNICATION , INFERENCE OF (CRIMINAL LAW, NO NEED FOR ARRESTING OFFICER TO TESTIFY AT SUPPRESSION HEARING, INFERENCE OF MUTUAL COMMUNICATION APPLIED)/SUPPRESSION (CRIMINAL LAW, EVIDENCE, NO NEED FOR ARRESTING OFFICER TO TESTIFY AT SUPPRESSION HEARING, INFERENCE OF MUTUAL COMMUNICATION APPLIED)

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BUILDING RESIDENTS CAN BRING CLASS ACTION AGAINST OWNERS-MANAGERS ALLEGING NEGLIGENCE IN PREPARATION FOR SUPERSTORM SANDY.

The First Department determined the residents of a building met the requirements for a class action suit alleging negligent failure to secure the building prior to Superstorm Sandy:

The court properly concluded that plaintiffs satisfied the criteria of CPLR 901, and the factors enumerated in CPLR 902 support class certification.

It is undisputed that the building has more than 400 residential apartments above 15 floors of commercial space. Thus, the numerosity requirement is met and joinder of all class members is impracticable … .

The commonality requirement is also satisfied in that the proof at trial will consist of evidence of defendants’ efforts to prevent damage in advance of the storm and to repair damage after the storm. Since the class consists of tenants of the building, common questions predominate over individual questions concerning the amount and type of damages sustained by each class member … . Any differences in proof with respect to the applicability of the warranty of habitability in Real Property Law § 235-b as between residential tenants and commercial tenants is insufficient to overcome the significant common questions, and the court may, in its discretion, establish subclasses … .

The claims of the putative class representatives are typical of the class’s claims since each resides or leases space in the building and their injuries, if any, derive from the same course of conduct by defendants … . Moreover, the record reflects that they are sufficiently informed about the facts, have no conflicts of interest with the class they seek to represent, and are able to act as a check on counsel … . Roberts v Ocean Prime, LLC, 2017 NY Slip Op 01974, 1st Dept 3-16-17

 

CIVIL PROCEDURE (BUILDING RESIDENTS COULD BRING CLASS ACTION AGAINST OWNERS-MANAGERS ALLEGING NEGLIGENCE IN PREPARATION FOR SUPERSTORM SANDY)/CLASS ACTIONS (BUILDING RESIDENTS COULD BRING CLASS ACTION AGAINST OWNERS-MANAGERS ALLEGING NEGLIGENCE IN PREPARATION FOR SUPERSTORM SANDY)/LANDLORD-TENANT (BUILDING RESIDENTS COULD BRING CLASS ACTION AGAINST OWNERS-MANAGERS ALLEGING NEGLIGENCE IN PREPARATION FOR SUPERSTORM SANDY)/SUPERSTORM SANDY (BUILDING RESIDENTS COULD BRING CLASS ACTION AGAINST OWNERS-MANAGERS ALLEGING NEGLIGENCE IN PREPARATION FOR SUPERSTORM SANDY)

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NO EXPECTATION OF PRIVACY IN EMAIL ACCOUNT OWNED BY ATTORNEY’S EMPLOYER, THEREFORE ATTORNEY CLIENT AND SPOUSAL PRIVILEGES DID NOT APPLY, ATTORNEY WORK PRODUCT PROTECTION MAY APPLY.

The First Department determined nonparty Perlmutter (attorney) did not have an expectation of privacy in an email account owned by his employer, Marvel. Therefore the emails were not protected by attorney client privilege or spousal privilege. However, some emails may be protected as attorney work product:

Application of the four factors set forth in In re Asia Global Crossing, Ltd. (322 BR 247, 257 [Bankr SD NY 2005]), which we endorse … , indicates that Perlmutter lacked any reasonable expectation of privacy in his personal use of the email system of Marvel, his employer, and correspondingly lacked the reasonable assurance of confidentiality that is an essential element of the attorney-client privilege … . Among other factors, while Marvel’s email policies during the relevant time periods permitted “receiving e-mail from a family member, friend, or other non-business purpose entity . . . as a courtesy,” the company nonetheless asserted that it “owned” all emails on its system, and that the emails were “subject to all Company rules, policies, and conduct statements.” Marvel “reserve[d] the right to audit networks and systems on a periodic basis to ensure [employees’] compliance” with its email policies. It also “reserve[d] the right to access, review, copy and delete any messages or content,” and “to disclose such messages to any party (inside or outside the Company).” Given, among other factors, Perlmutter’s status as Marvel’s Chair, he was, if not actually aware of Marvel’s email policy, constructively on notice of its contents

Perlmutter’s use of Marvel’s email system for personal correspondence with his wife waived the confidentiality necessary for a finding of spousal privilege … .

Given the lack of evidence that Marvel viewed any of Perlmutter’s personal emails, and the lack of evidence of any other actual disclosure to a third party, Perlmutter’s use of Marvel’s email for personal purposes does not, standing alone, constitute a waiver of attorney work product protections … . Peerenboom v Marvel Entertainment, LLC, 2017 NY Slip Op 01981, 1st Dept 3-16-17

 

ATTORNEYS (NO EXPECTATION OF PRIVACY IN EMAIL ACCOUNT OWNED BY ATTORNEY’S EMPLOYER, THEREFORE ATTORNEY CLIENT AND SPOUSAL PRIVILEGES DID NOT APPLY)/PRIVILEGE (NO EXPECTATION OF PRIVACY IN EMAIL ACCOUNT OWNED BY ATTORNEY’S EMPLOYER, THEREFORE ATTORNEY CLIENT AND SPOUSAL PRIVILEGES DID NOT APPLY)/ATTORNEY CLIENT PRIVILEGE (NO EXPECTATION OF PRIVACY IN EMAIL ACCOUNT OWNED BY ATTORNEY’S EMPLOYER, THEREFORE ATTORNEY CLIENT AND SPOUSAL PRIVILEGES DID NOT APPLY)/SPOUSAL PRIVILEGE (NO EXPECTATION OF PRIVACY IN EMAIL ACCOUNT OWNED BY ATTORNEY’S EMPLOYER, THEREFORE ATTORNEY CLIENT AND SPOUSAL PRIVILEGES DID NOT APPLY)/ATTORNEY WORK PRODUCT (NO EXPECTATION OF PRIVACY IN EMAIL ACCOUNT OWNED BY ATTORNEY’S EMPLOYER, THEREFORE ATTORNEY CLIENT AND SPOUSAL PRIVILEGES DID NOT APPLY, ATTORNEY WORK PRODUCT PROTECTION MAY APPLY)

ATTORNEY MISCONDUCT CLAIM UNDER JUDICIARY LAW 487 APPLIES ONLY TO COURT, NOT ARBITRATION, PROCEEDINGS.

The First Department noted that a Judiciary Law 487 claim against attorneys for misconduct does not apply to alleged misconduct in arbitration, as opposed to court, proceedings:

Plaintiff … failed to state a cause of action under Judiciary Law § 478, because the statute does not apply to attorney misconduct during an arbitral proceeding. The plain text of § 478 limits the statute’s application to conduct deceiving “the court or any party” … , and, because the statute has a criminal component, it must be interpreted narrowly … . Moreover, courts have held that the statute does not apply to conduct outside New York’s territorial borders or to administrative proceedings, observing that its purpose is to regulate the manner in which litigation is conducted before the courts of this State … .

In any event, plaintiff failed to allege the elements of a cause of action under the statute, i.e., intentional deceit and damages proximately caused by the deceit … .  The misconduct that plaintiff alleges is not “egregious” or “a chronic and extreme pattern of behavior” … and the allegations regarding scienter lack the requisite particularity … . Doscher v Mannatt, Phelps & Phillips, LLP, 2017 NY Slip Op 01973, 1st Dept 3-16-17

 

ATTORNEYS (ATTORNEY MISCONDUCT CLAIM UNDER JUDICIARY LAW 487  APPLIES ONLY TO COURT, NOT ARBITRATION, PROCEEDINGS)/JUDICIIARY LAW 487 (ATTORNEY MISCONDUCT CLAIM UNDER JUDICIARY LAW 487 APPLIES ONLY TO COURT, NOT ARBITRATION, PROCEEDINGS)/ARBITRATION (ATTORNEY MISCONDUCT, ATTORNEY MISCONDUCT CLAIM UNDER JUDICIARY LAW 487 APPLIES ONLY TO COURT, NOT ARBITRATION, PROCEEDINGS)

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ALTHOUGH THE FIRST DEPT FELT CONSTRAINED BY COURT OF APPEALS PRECEDENT TO DISMISS THIS DOG INJURY CASE SOUNDING IN NEGLIGENCE, THE COURT FORCEFULLY ARGUED THE LAW SHOULD BE CHANGED TO ALLOW SUCH A SUIT.

The First Department, in a substantial opinion by Justice Acosta, reluctantly affirmed Supreme Court’s dismissal of the dog-injury complaint. Defendant tied his 35 pound dog to an unsecured bicycle rack which weighed five pounds. The dog ran off, dragging the rack. Plaintiff’s leg became tangled in the rack, causing him to fall. The First Department followed the Court of Appeals precedent, which allows a dog-injury suit only on vicious propensity/strict liability grounds. The opinion strongly argued the law should be changed to allow dog-injury suits based upon negligence:

Were we not … constrained … we would … permit plaintiffs to pursue their negligence cause of action. To avoid the harshness of the [Court of Appeals] rule, the recognition of the following exception would be appropriate: A dog owner who attaches his or her dog to an unsecured, dangerous object, allowing the dog to drag the object through the streets and cause injury to others, may be held liable in negligence. In these circumstances, negligence liability would be in keeping with the principles of fundamental fairness, responsibility for one’s actions, and societal expectations … — assuming a jury would deem unreasonable defendant’s failure to ensure that the rack was secured before he tied his dog to it. It is not unreasonable to expect dog owners to restrain their dogs in public unless unleashing them is safe or specifically permitted at certain times and locations, as evidenced by local leash laws (see e.g. 24 RCNY 161.05). However, the Court of Appeals has decided that local leash laws have no bearing on whether liability in negligence ought to attach … , undermining the declared public policy of those localities that have enacted such laws … And although the [Court of Appeals] reasoned that New Yorkers may expect to find unrestrained dogs in public parks … , New Yorkers certainly do not expect to find those dogs running on public roads towing large metal objects behind them. A dog owner who, without observing a reasonable standard of care, attaches his or her dog to an object that could foreseeably become weaponized if the dog is able to drag the object through public areas should not be immune from liability when that conduct causes injury. Scavetta v Wechsler, 2017 NY Slip Op 01985, 1st Dept 3-16-17

ANIMAL LAW (ALTHOUGH THE FIRST DEPARTMENT FELT CONSTRAINED BY COURT OF APPEALS PRECEDENT TO DISMISS THIS DOG INJURY CASE SOUNDING IN NEGLIGENCE, THE COURT FORCEFULLY ARGUED THE LAW SHOULD BE CHANGED TO ALLOW SUCH A SUIT)/DOGS (ALTHOUGH THE FIRST DEPARTMENT FELT CONSTRAINED BY COURT OF APPEALS PRECEDENT TO DISMISS THIS DOG INJURY CASE SOUNDING IN NEGLIGENCE, THE COURT FORCEFULLY ARGUED THE LAW SHOULD BE CHANGED TO ALLOW SUCH A SUIT)/NEGLIGENCE (DOGS, ALTHOUGH THE FIRST DEPARTMENT FELT CONSTRAINED BY COURT OF APPEALS PRECEDENT TO DISMISS THIS DOG INJURY CASE SOUNDING IN NEGLIGENCE, THE COURT FORCEFULLY ARGUED THE LAW SHOULD BE CHANGED TO ALLOW SUCH A SUIT)

QUESTION OF FACT WHETHER NEGLIGENT WAXING WAS CAUSE OF PLAINTIFF’S FALL.

The First Department determined there was a question of fact whether plaintiff’s slip and fall was caused by excessive wax on the floor:

Defendants established entitlement to judgment as a matter of law in this action where plaintiff alleges that she was injured when she slipped on a floor that was negligently waxed. Defendants submitted evidence showing that the floor was last waxed approximately three months before plaintiff’s fall … . In opposition, plaintiff raised triable issues as to whether “a dangerous residue of wax was present” … . She stated that after she fell, there was wax on her hands and, when she stepped on the waxy area, she saw a “scuff mark” running through a circular area, creating a “sunken stripe through the wax.” Plaintiff slid her foot back and forth on the circular patch, and felt the “accumulated, raised, substance on the floor” move with the pressure of her foot, and these actions were captured on the building’s security footage. Sanchez v Mitsui Fudosan Am., Inc., 2017 NY Slip Op 01821, 1st Dept 3-15-17

NEGLIGENCE (SLIP AND FALL, QUESTION OF FACT WHETHER NEGLIGENT WAXING WAS CAUSE OF PLAINTIFF’S FALL)/SLIP AND FALL (QUESTION OF FACT WHETHER NEGLIGENT WAXING WAS CAUSE OF PLAINTIFF’S FALL)/WAX (SLIP AND FALL, QUESTION OF FACT WHETHER NEGLIGENT WAXING WAS CAUSE OF PLAINTIFF’S FALL)

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