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Law School Case Brief

Battalla v. State - 10 N.Y.2d 237, 219 N.Y.S.2d 34, 176 N.E.2d 729 (1961)

Rule:

It is fundamental to our common-law system that one may seek redress for every substantial wrong. The best statement of the rule is that a wrong-doer is responsible for the natural and proximate consequences of his misconduct; and what are such consequences must generally be left for the determination of the jury.

Facts:

Plaintiff C.B., an infant, by her guardian ad litem, Carmen Battalla, filed a lawsuit in the New York court of claims against defendant State o New York, seeking to recover damages for injuries sustained by C.B. According to the compliant, C.B. was negligently caused to suffer severe emotional and neurological disturbances with residual physical manifestations because a State employee at a ski center negligently failed to secure and properly lock the belt intended to protect the occupant and, as a result of that alleged negligent act, C.B. became frightened and hysterical upon the descent, with consequential injuries. to fasten a safety belt after placing C.B. on a chair lift. The State filed a motion to dismiss, arguing that, under precedent from the Court of Appeals of New York, namely Mitchell v. Rochester Ry. Co., there was no cause of action for the negligent infliction of emotional distress. The court of claims denied the motion to dismiss, finding that C.B. had a viable cause of action. On the State's appeal, the appellate division reversed, relying Mitchell. C.B. appealed.

Issue:

Did a claim alleging that a claimant was negligently caused to suffer severe emotional and neurological disturbances with residual physical manifestations state a cause of action?

Answer:

Yes.

Conclusion:

The Court of Appeals of New York reversed the appellate division's judgment and reinstated the order of the court of claims. Th court expressly overruled Mitchell, which barred claims such as C.B.'s, which was essentially one for negligent infliction of emotional distress. The court reasoned that the Mitchell rule was unjust, as well as opposed to experience and logic because an injured party should have been capable of bringing an action against a wrongdoer for injuries caused by him or her.In many instances, just as in impact cases, there will be no doubt as to the presence and extent of the damage and the fact that it was proximately caused by defendant's negligence. In the difficult cases, the court explained, the courts must look to the quality and genuineness of proof, and rely to an extent on the contemporary sophistication of the medical profession and the ability of the court and jury to weed out dishonest claims. C.B. was entitled to prove that her injuries were proximately caused by the State's negligence.

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