Ossining Urban Renewal Agency v. Lord, 60 N.Y.2d 845 (1983)
A stipulation between parties in a CPLR 3222 submission is conclusive of the facts stated therein and binds the parties throughout the proceedings, even if those facts are later proven to be inaccurate or based on erroneous assumptions.
Summary
This case addresses the enforceability of factual stipulations made by parties in a legal proceeding, specifically within the context of an eminent domain dispute. The Ossining Urban Renewal Agency (OURA) stipulated that Pine Top Building Corp.’s easement provided the only access to a public road. Later, OURA argued the easement was valueless because it crossed state land. The Court of Appeals held that OURA was bound by its stipulation, regardless of the true nature of Pine Top’s access rights, and that the commissioners of appraisal erred by undervaluing the easement based on the incorrect assumption that it provided no such access.
Facts
Elissa Lord conveyed a 13.68-acre parcel to Pine Top Building Corp., granting an easement for ingress and egress. The easement purported to cross both Lord’s remaining 5.5-acre parcel and state-owned land to reach Snowden Avenue, a public road. In subsequent eminent domain proceedings initiated by the Ossining Urban Renewal Agency (OURA), OURA stipulated that the easement represented Pine Top’s *only* access to a public road. Later, the easement was extinguished. The state ultimately abandoned the highway.
Procedural History
The Supreme Court made an initial order that was later reinstated by the Court of Appeals in a prior decision (Matter of Ossining Urban Renewal Agency v Lord, 39 N.Y.2d 628). The commissioners of appraisal evaluated the condemned easement, concluding it provided no right of passage over state land, thus diminishing its value. Pine Top appealed. The Appellate Division’s order was reversed by the Court of Appeals, remanding the matter to the Supreme Court, who would then remand to the commissioners of appraisal.
Issue(s)
Whether the Ossining Urban Renewal Agency was bound by its prior stipulation that Pine Top’s easement provided the only access to a public road, despite arguing later that the easement was valueless because it crossed state land.
Holding
Yes, because the CPLR 3222 submission constituted a binding stipulation of facts. The Agency, having stipulated to the easement’s function as the only access route, was bound by that concession, regardless of the actual nature of Pine Top’s right to cross state land.
Court’s Reasoning
The Court of Appeals relied heavily on the principle that stipulations between parties are binding. Citing Mann v Simpson & Co., 286 N.Y. 450, the court emphasized that the CPLR 3222 submission was