Peralta v. Henriquez, 100 N.Y.2d 139 (2003)

A landowner has a duty to maintain property in a reasonably safe condition, considering the likelihood of injury to others, the potential seriousness of such injury, and the burden of avoiding the risk; the presence of adequate lighting is a factor in determining reasonable safety.

Summary

The New York Court of Appeals addressed the duty of a landowner to provide adequate lighting on their property. The plaintiff, a houseguest, was injured while walking through an unlit parking lot owned by the defendants. The Court held that landowners have a duty to maintain their property in a reasonably safe condition, which may include providing adequate lighting, but rejected the notion that an unlit lot is per se dangerous. The Court emphasized that the duty is not a generalized one, and the jury should determine whether the defendants knew or should have known that the existing lighting was inadequate given the use and design of the lot.

Facts

Raphael and Aurora Henriquez owned two buildings and an adjacent unpaved parking lot. Residents and guests used the lot, and it was also used as a