Tibbs v. De'Longhi Am. Inc.

Tibbs v. De'Longhi Am. Inc. 2025 NY Slip Op 00033 · Appellate Division, First Department · January 2, 2025 · No. 150421/19

Summary

This Appellate Division, First Department decision affirms the Supreme Court's denial of plaintiffs' motion for partial summary judgment on liability in a motor vehicle accident personal injury action. The court held that conflicting deposition testimony regarding lane positioning created issues of fact precluding a finding that the defendant driver violated Vehicle and Traffic Law § 1128(a) as a matter of law. Consequently, the plaintiffs failed to meet their prima facie burden to establish defendant negligence.

Court
Appellate Division, First Department
Writing for the Court
Kern, J.P.; Kapnick; González; Mendez; O'Neill Levy
Jurisdiction
New York
Decision date
January 2, 2025
Docket number
150421/19
Procedural posture
Appeal from Supreme Court, New York County order denying plaintiffs' motion for partial summary judgment.
Precedential value
published
Parties
Kevin R. Tibbs, et al. v. De'Longhi America Inc., et al.
Disposition
affirmed

Topics

personal injurynegligencesummary judgmentcivil procedure

Practice areas

tortscivil procedure

Questions Presented

  1. Whether defendants violated Vehicle and Traffic Law § 1128(a) such that they are liable as a matter of law for the accident
  2. Whether plaintiffs established a prima facie case for summary judgment on liability

Holdings

  1. Plaintiffs failed to establish that defendants violated Vehicle and Traffic Law § 1128(a); therefore the motion for partial summary judgment was denied.

Factual background

On July 20, 2018, a motor‑vehicle accident occurred near West Street and North Moore in Manhattan. Plaintiff Lydia Cross was a front‑seat passenger in a vehicle driven by her son, Kevin R. Tibbs. Defendant Viktoria Rogulska was operating a corporate car owned by De'Longhi America Inc. The collision involved a side‑swipe as the vehicles merged into the same lane.

Procedural history

The Supreme Court, New York County denied plaintiffs' motion for partial summary judgment on liability and entered an order on October 6, 2023. The plaintiffs appealed that order to the Appellate Division, First Department.

Court Document

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