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Durrans v. Harrison & Burrowes Bridge Constructors, Inc.

Citations: 128 A.D.3d 1136; 8 N.Y.S.3d 700

Court: Appellate Division of the Supreme Court of the State of New York; May 7, 2015; New York; State Appellate Court

Narrative Opinion Summary

In this case, the appellant contested two decisions from the Supreme Court in Albany County concerning a negligence claim against a construction company contracted by the Department of Transportation. The plaintiff was injured after her bicycle struck a recessed manhole cover while following a detour that included orange barrels placed by the defendant. The court initially granted partial summary judgment, dismissing the complaint based on the defendant's lack of contractual duty to address existing road conditions, as the maintenance responsibility was assigned to the Town. During the trial, the jury found the defendant negligently placed the barrels but ruled this was not a significant cause of the injuries. The plaintiff's motion to set aside the verdict was denied, prompting an appeal. The appellate court found the denial of the motion improper, noting that the defendant's actions contributed to the hazardous condition, even though the plaintiff's behavior might have been a superseding cause. Consequently, the judgment was reversed, the motion to set aside the verdict was granted, and the case was remanded for a new trial. The plaintiff's appeal from the interlocutory order was dismissed as moot following the final judgment, allowing the appeal from the judgment to proceed without costs.

Legal Issues Addressed

Appeal and Reversal of Verdict

Application: The Supreme Court erred in denying the plaintiff's motion to set aside the verdict, resulting in the judgment being reversed and a new trial ordered.

Reasoning: The appeal from the order is dismissed without costs, the judgment is reversed, the motion to set aside the verdict is granted, and the case is remitted for a new trial, with costs to follow the event.

Duty of Care and Contractual Obligations

Application: The defendant was not found to have displaced the Department of Transportation's duty because the contract assigned maintenance duties to the Town.

Reasoning: The defendant was granted summary judgment as it did not fully displace DOT's duty to maintain safety on the roadway, as the Town was responsible for maintaining pavement and sewers per the contract.

Negligence and Proximate Cause

Application: Although the jury found the defendant negligent in placing barrels, they determined it was not a substantial factor in causing the plaintiff's injuries.

Reasoning: Although the jury found the defendant negligent, they concluded that this negligence wasn’t a substantial factor in the plaintiff's injury.

Summary Judgment in Negligence Cases

Application: The court partially granted summary judgment dismissing the negligence complaint against the defendant, as they had no contractual obligation to repair the manhole cover.

Reasoning: The defendant, a construction company working under contract with the Department of Transportation (DOT), argued it owed no duty to McCarthy regarding this existing condition.

Superseding Cause in Negligence

Application: The jury considered the plaintiff's actions, potentially constituting a superseding cause, but found defendant's negligence in placing barrels as a contributing factor.

Reasoning: A plaintiff's conduct can serve as a superseding cause that severs the link between a defendant's negligence and the injury, particularly when the plaintiff's negligence exceeds mere contributory negligence.