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McCullough v. Riverbay Corp.

Citations: 2017 NY Slip Op 4231; 150 A.D.3d 624; 52 N.Y.S.3d 854Docket: 4141

Court: Appellate Division of the Supreme Court of the State of New York; May 30, 2017; New York; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In the case of McCullough v. Riverbay Corp., the Appellate Division of the New York Supreme Court addressed a negligence claim concerning a sidewalk defect allegedly causing a trip and fall incident. The action involved the plaintiff, who argued that a significant sidewalk defect led to her injuries, and the defendant, Riverbay Corporation, who contended that the defect was minor. The procedural history included a denial of summary judgment by the Bronx County Supreme Court, which was subsequently reversed by the Appellate Division. The court granted summary judgment in favor of Riverbay, concluding that the defect, a height differential of less than half an inch, was trivial. Photographic evidence showed no jagged edges or irregular surfaces, and the plaintiff's assertion of a more significant defect was unsupported by measurements. The absence of exacerbating circumstances further supported the court's decision, leading to the dismissal of the plaintiff's complaint. The appellate court's ruling underscores the application of the trivial defect doctrine, emphasizing the need for concrete evidence in establishing negligence.

Legal Issues Addressed

Evidence Evaluation in Summary Judgment

Application: Photographs and measurements provided by Riverbay were persuasive to the court in determining the triviality of the defect.

Reasoning: Riverbay established that the height differential between the sidewalk and the expansion joint was less than half an inch, supported by submitted photographs and measurements.

Speculative Claims in Negligence Cases

Application: The plaintiff's claim regarding the defect's height was considered speculative due to the lack of concrete measurements.

Reasoning: McCullough's claim that the defect was two to four inches high was deemed speculative, as she did not provide a measurement.

Summary Judgment Standards

Application: The court granted summary judgment in favor of Riverbay Corporation, demonstrating that the defect in question was trivial and did not pose a significant danger.

Reasoning: The Appellate Division of the New York Supreme Court reversed a prior order from the Bronx County Supreme Court that had denied Riverbay Corporation's motion for summary judgment.

Trivial Defect Doctrine

Application: The court found the sidewalk defect to be trivial, as the height differential was less than half an inch and lacked jagged edges or irregular surfaces.

Reasoning: The court granted the motion, concluding that the sidewalk defect, which allegedly caused the plaintiff, Audrey McCullough, to trip and fall, was trivial.