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Stone v. Bridgehampton Race Circuit

Citations: 244 A.D.2d 403; 665 N.Y.S.2d 554; 1997 N.Y. App. Div. LEXIS 11259

Court: Appellate Division of the Supreme Court of the State of New York; November 9, 1997; New York; State Appellate Court

Narrative Opinion Summary

In a personal injury case, the plaintiff appeals an order from the Supreme Court of Westchester County that denied her request to renew a previous motion aimed at dismissing the defendants' assertion of a defense based on release and waiver. The appellate court affirms the order with costs, referencing a prior decision that dismissed the plaintiff's complaint, which limited the Supreme Court's ability to review the merits of the plaintiff's subsequent motion unless new facts emerged that could not have been presented earlier. Although the plaintiff provided new information in support of her motion, it was not materially inconsistent with the earlier information that formed the basis of the prior decision. Consequently, the court concludes that renewal is not justified, as the new evidence is merely cumulative of what was previously submitted. Judges Mangano, P.J., Bracken, Altman, and Goldstein concur in the decision.

Legal Issues Addressed

Cumulative Evidence in Motion Renewal

Application: Renewal is not justified when the new evidence presented in support of a motion is merely cumulative of what was previously submitted.

Reasoning: Consequently, the court concludes that renewal is not justified, as the new evidence is merely cumulative of what was previously submitted.

Limitations on Review of Prior Decisions

Application: The appellate court affirms that the lower court's ability to review the merits of a subsequent motion is limited when the original complaint has been dismissed, unless new facts are presented that could not have been presented earlier.

Reasoning: The appellate court affirms the order with costs, referencing a prior decision that dismissed the plaintiff's complaint, which limited the Supreme Court's ability to review the merits of the plaintiff's subsequent motion unless new facts emerged that could not have been presented earlier.

Renewal of Motion in Civil Procedure

Application: The court determines that a motion to renew can be denied if the new evidence presented is not materially inconsistent with the earlier evidence and merely cumulative.

Reasoning: Although the plaintiff provided new information in support of her motion, it was not materially inconsistent with the earlier information that formed the basis of the prior decision.