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Lloyd v. Town of Wheatfield

Citations: 67 N.Y.2d 809; 501 N.Y.S.2d 323; 492 N.E.2d 396; 1986 N.Y. LEXIS 17526

Court: New York Court of Appeals; March 19, 1986; New York; State Supreme Court

Narrative Opinion Summary

The Court of Appeals of the State of New York affirmed the Appellate Division's order, concluding that the plaintiffs, Gregory J. Lloyd et al., could not sustain their causes of action for damages due to purely economic loss, which were deemed too speculative as a matter of law. The court referenced prior cases, including Tobin v Grossman and Battalla v State of New York, emphasizing that damages must be proximate, non-speculative, and reasonably foreseen as a consequence of the alleged wrongdoing. The court did not address whether the actions of the defendant's building inspector were discretionary or ministerial. The decision upheld the dismissal of the complaint and awarded costs to the respondent, Town of Wheatfield.

Legal Issues Addressed

Discretionary vs. Ministerial Actions

Application: The court did not address whether the actions of the defendant's building inspector were discretionary or ministerial, leaving this issue unresolved.

Reasoning: The court did not address whether the actions of the defendant's building inspector were discretionary or ministerial.

Dismissal of Complaint and Costs

Application: The court upheld the dismissal of the complaint and awarded costs to the respondent, reinforcing the decision to not allow recovery for speculative economic loss.

Reasoning: The decision upheld the dismissal of the complaint and awarded costs to the respondent, Town of Wheatfield.

Economic Loss Rule

Application: The court determined that the plaintiffs could not recover damages for purely economic loss as such damages were deemed too speculative.

Reasoning: The Court of Appeals of the State of New York affirmed the Appellate Division's order, concluding that the plaintiffs, Gregory J. Lloyd et al., could not sustain their causes of action for damages due to purely economic loss, which were deemed too speculative as a matter of law.

Proximate and Foreseeable Damages

Application: The court emphasized the necessity for damages to be proximate, non-speculative, and reasonably foreseen as a consequence of the alleged wrongdoing.

Reasoning: The court referenced prior cases, including Tobin v Grossman and Battalla v State of New York, emphasizing that damages must be proximate, non-speculative, and reasonably foreseen as a consequence of the alleged wrongdoing.