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Fix v. B&B Mall Associates, Inc.

Citations: 118 A.D.3d 477; 987 N.Y.S.2d 384

Court: Appellate Division of the Supreme Court of the State of New York; June 10, 2014; New York; State Appellate Court

Narrative Opinion Summary

This case involved a dispute over the appropriate venue for a personal injury lawsuit following a slip and fall incident in a parking lot in Westchester County. The plaintiff chose Bronx County as the venue, asserting it was the principal place of business for B&B Mall Associates, Inc. B&B Mall sought to change the venue to Westchester County, providing an affidavit from its president to support its claim. However, the affidavit lacked necessary documentary evidence, leading the Supreme Court of Bronx County to find it insufficient. The plaintiffs presented contrary evidence, including official documentation from the New York State Department of State, confirming Bronx County as B&B Mall’s principal place of business. The court found this evidence compelling and denied the motion to change venue. The appellate court affirmed this decision unanimously, ruling that the plaintiff's choice of venue was proper. The court also dismissed B&B Mall's additional arguments as unpersuasive, leading to a resolution in favor of maintaining the venue in Bronx County without costs.

Legal Issues Addressed

Appellate Review of Venue Decisions

Application: The appellate court unanimously affirmed the lower court's decision to maintain the venue in Bronx County.

Reasoning: The court affirmed the decision without costs and found B&B Mall's additional arguments unpersuasive. The ruling was unanimous among the justices: Gonzalez, Sweeny, Moskowitz, Freedman, and Kapnick.

Role of Documentary Evidence in Venue Challenges

Application: Documentary evidence indicating an officially designated principal place of business was pivotal in affirming the venue.

Reasoning: The plaintiffs countered with documentary evidence indicating that B&B Mall had an office in Bronx County and had officially designated Bronx County as its principal place of business with the state.

Sufficiency of Evidence in Venue Disputes

Application: An affidavit lacking supporting documentary evidence was deemed insufficient to contest the venue designation.

Reasoning: B&B Mall argued that its principal place of business was in Westchester County and provided an affidavit from its president, which lacked supporting documentary evidence to substantiate this claim.

Venue Determination Based on Principal Place of Business

Application: The court determined venue based on the officially designated principal place of business as filed with the state, rather than the location of the incident.

Reasoning: The plaintiff, Mary Fix, sustained injuries from a slip and fall in a parking lot located in Westchester County, but designated Bronx County as the venue based on B&B Mall’s principal place of business.