Wednesday, January 1, 2014

Sindle v. New York Transit Authority case brief

Sindle v. New York Transit Authority case brief summary
352 N.Y.S.2d 183 (1973)

Defendant transit authority appealed the Appellate Division of New York's judgment in favor of plaintiff, which held that defendants were liable for plaintiff's injuries when plaintiff jumped out of bus, on theory of false imprisonment.

Plaintiff boarded school bus, which while on its afternoon route experienced vandalism from students. Driver told students he was taking them to police department. En route, plaintiff either jumped or fell from bus, and was injured. Plaintiff sued to recover damages for negligence and false imprisonment, but proceeded only on theory of false imprisonment.


  • At the close of plaintiff's case, the lower court denied defendants' motion to amend answers to plead defensive justification. 
  • The lower court also excluded all evidence bearing on justification.
  • Judgment was entered for plaintiff, and defendants appealed. 
  • The Court held it was an abuse of discretion by lower court to deny motion to amend and to exclude evidence, as granting motion would not prejudice plaintiff and failure to grant motion was manifestly unfair to defendants. 
  • Further, the court held at retrial if plaintiff's negligence in attempting to extricate himself from unlawful confinement caused his injuries, his action should diminish his damages.

Order of lower court reversed and case remanded for new trial as defendants' motion to amend should have been granted and evidence regarding justification necessary to trial.

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