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Newisky v. United Artists Kaufman Astoria 14 Regal Cinemas

Citation: 2018 NY Slip Op 6880Docket: 2017-02264

Court: Appellate Division of the Supreme Court of the State of New York; October 17, 2018; New York; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In the case concerning personal injuries allegedly sustained by the plaintiff at the defendants' movie theater, the plaintiff claimed damages following a fall caused by a dislodged seat cushion. The defendants sought summary judgment, arguing lack of creation or notice of the defect and challenged the applicability of res ipsa loquitur. The Supreme Court of Queens County initially denied the motion, but the Appellate Division reversed this decision. The appellate court found that the defendants had demonstrated a prima facie case showing no notice of the defect and that the plaintiff failed to raise a triable issue. Additionally, the court held that res ipsa loquitur was inapplicable, as the evidence did not rule out third-party interference with the seat. Consequently, the Appellate Division granted summary judgment in favor of the defendants, dismissing the complaint with costs, thereby resolving the case in the defendants' favor. The decision was concluded by a panel of justices, and the case was formally closed by the clerk of the court.

Legal Issues Addressed

Doctrine of Res Ipsa Loquitur

Application: The court determined that the doctrine of res ipsa loquitur was inapplicable as the plaintiff failed to exclude the possibility of third-party interference with the seat's condition.

Reasoning: The court ruled that the evidence did not sufficiently exclude the possibility that the seat had been damaged by someone other than the defendants, thereby rendering the application of res ipsa loquitur inappropriate.

Notice Requirement in Premises Liability

Application: Defendants were found not liable as the plaintiff could not establish that they had actual or constructive notice of the hazardous condition.

Reasoning: The defendants, United Artists Kaufman Astoria 14 Regal Cinemas, filed a motion for summary judgment to dismiss the complaint, arguing they neither created nor had actual or constructive notice of the seat's defective condition.

Summary Judgment Standards

Application: The defendants successfully demonstrated the absence of notice regarding the defective seat condition, thereby justifying the grant of summary judgment.

Reasoning: Upon appeal, the Appellate Division found that the defendants had demonstrated, prima facie, that they lacked notice of the defect and had not contributed to its existence.