95 N.Y.2d 95 (2000)
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A municipality’s duty of care extends only to specific individuals or classes of individuals, not the public at large, and a ministerial breach by a government employee does not automatically create municipal liability unless a specific duty to the plaintiff is established.
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Summary
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This case addresses whether the City of New York could be held liable for the Medical Examiner’s negligence in failing to correct an autopsy report and death certificate that initially identified a child’s death as a homicide, leading to the father becoming a suspect. The Court of Appeals held that the city was not liable because the Medical Examiner’s duty was to the public at large, not to the father specifically. The Court emphasized that a ministerial breach, while not immunized, does not automatically equate to tortious conduct; a specific duty to the injured party must exist for municipal liability to arise. The court declined to expand the scope of duty in this context, citing policy concerns about the potential for limitless liability against municipalities.
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Facts
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Three-year-old Andrew Lauer died. A New York City Medical Examiner, Dr. Lilavois, performed an autopsy and incorrectly concluded the death was a homicide caused by blunt injuries. Based on this report, police investigated Andrew’s father, the plaintiff, as a suspect. Weeks later, a more detailed examination revealed the death was caused by a ruptured brain aneurysm, contradicting the initial finding. Dr. Lilavois failed to correct the autopsy report, death certificate, or notify law enforcement. The plaintiff suffered emotional distress, marital breakdown, and social ostracization as a result of the ongoing homicide investigation against him. The error was corrected 17 months later following a newspaper report, and the Medical Examiner resigned.
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Procedural History
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Plaintiff sued the City of New York, the Office of the Chief Medical Examiner, Dr. Lilavois, and the Police Department, alleging defamation, civil rights violations, and negligent/intentional infliction of emotional distress. The Supreme Court dismissed the defamation and civil rights claims but allowed the emotional distress claims to proceed. The Appellate Division modified, dismissing the intentional infliction of emotional distress claim and any claims based on the initial autopsy. However, the Appellate Division allowed the negligent infliction of emotional distress claim based on the failure to correct the reports, leading to this appeal.
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Issue(s)
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Whether the City of New York can be held liable for negligent infliction of emotional distress based on the Medical Examiner’s failure to correct an erroneous autopsy report, death certificate, and notify authorities when the duty to do so was allegedly ministerial.
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Holding
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No, because the Medical Examiner’s duty to accurately report findings was a general duty owed to the public, not a specific duty owed to the plaintiff, and therefore the plaintiff cannot maintain a claim for negligent infliction of emotional distress.
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Court’s Reasoning
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The Court acknowledged that municipalities are not immune from liability for their employees’ negligence. However, a distinction exists between discretionary and ministerial acts. While the Medical Examiner’s failure to correct the record was ministerial, a ministerial breach does not automatically lead to municipal liability. A duty must run directly to the injured person. The Court found that New York City Charter § 557, which requires the Medical Examiner to report findings to the District Attorney, is intended to benefit the public at large, not individual suspects in criminal investigations. Therefore, the statute does not create a specific duty to the plaintiff. The Court also rejected the argument that a