532 Madison Avenue Gourmet Foods, Inc. v. Finlandia Center, Inc. case brief

532 Madison Avenue Gourmet Foods, Inc. v. Finlandia Center, Inc. case brief summary
750 N.E.2d 1097 (N.Y. 2001)

SYNOPSIS: In consolidated appeal of first of two cases, defendant construction contractors and landowners appealed Supreme Court, Appellate Division (New York), reversal of dismissal of plaintiff nearby businesses' actions to recover economic loss suffered from street closure after accident; in second case, plaintiffs appealed affirmance of dismissal of their actions.

OVERVIEW: Plaintiffs in two sets of consolidated cases suffered severe economic losses from business and street closures that resulted from defendants' construction project disasters. Inconsistent intermediate appellate court rulings on whether plaintiffs could recover for their losses led to review by New York's high court.

HOLDING:
The court held that in both these cases, plaintiffs could not show that they had any sort of special relationship with their respective defendants that justified imposing a duty of care toward plaintiffs on defendants.

ANALYSIS:
-Furthermore, plaintiffs could not show that the harm they suffered was any different from the harm suffered by all the businesses in their urban neighborhoods.
-Liability could not reasonably be extended so far, so defendants were not liable under a theory of nuisance, either.

RULES:
-A New York landowner who engages in activities that may cause injury to persons on adjoining premises surely owes those persons a duty to take reasonable precautions to avoid injuring them. -However, a landowner does not owe a duty to protect an entire urban neighborhood against purely economic losses.

OUTCOME: The court reversed in one pair of cases and affirmed in the other. Since all the plaintiffs were damaged so similarly to other parties, too numerous to be granted relief, there was no special relationship permitting any of them to recover damages.

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