Bernard v. County of Rensselaer, 68 N.Y.2d 726 (1986)

A claim against a Sheriff’s Department for negligence in maintaining a safe environment for inmates in a county jail is subject to a one-year statute of limitations under CPLR 215(1) because it relates to the Sheriff’s official duty to safely keep inmates.

Summary

Plaintiff Bernard sued Rensselaer County and the Sheriff’s Department, alleging negligence for injuries sustained due to a slippery floor in the Rensselaer County Jail. The Court of Appeals addressed whether the one-year statute of limitations in CPLR 215(1) applied to the negligence claim against the Sheriff’s Department. The Court held that the claim was indeed subject to the one-year statute of limitations because the Sheriff has a statutory duty to safely keep inmates, and the negligence action stemmed from an alleged breach of that official duty. Therefore, the action, filed after one year, was time-barred.

Facts

Plaintiff Bernard allegedly sustained injuries as a result of a pool of liquid on the floor of the Rensselaer County Jail. Bernard subsequently filed a negligence action against Rensselaer County and the Rensselaer County Sheriff’s Department.

Procedural History

The lower court’s decision regarding the statute of limitations was appealed to the Appellate Division. The Appellate Division’s order was then appealed to the New York Court of Appeals. The Court of Appeals reversed the Appellate Division’s order, dismissing the first cause of action.

Issue(s)

Whether a negligence action against a Sheriff’s Department, alleging failure to maintain a safe environment in a county jail, is subject to the one-year statute of limitations set forth in CPLR 215(1) for actions against a Sheriff for acts done in an official capacity or omission of an official duty?

Holding

Yes, because the duty to safely keep inmates is imposed upon a Sheriff by his office, and the negligence action is based on an alleged breach of that duty. Thus, CPLR 215(1) applies, and the action must be commenced within one year.

Court’s Reasoning

The Court reasoned that CPLR 215(1) provides a one-year statute of limitations for actions against a Sheriff for liabilities incurred by acts done in their official capacity or omission of an official duty. This limitation period is coextensive with the liability against which a Sheriff must be bonded. County Law § 403 requires the Sheriff to execute an undertaking to faithfully discharge the duties of the office, as defined in Public Officers Law § 11. County Law § 650(1) defines these duties as those prescribed by law as an officer of the court and conservator of the peace, as well as additional and related duties prescribed by law. Specifically, Correction Law § 500-c prescribes that the Sheriff must safely keep inmates of the County Jail. The court distinguished this case from Dixon v. Seymour, where the duty of a deputy sheriff to use reasonable care while operating a vehicle was a general duty, not one imposed by their office. Here, the duty to safely keep is specifically imposed upon the Sheriff by virtue of their office. The court stated, “As the duties of the Sheriff are those ‘prescribed by law as an officer of the court and conservator of the peace * * * [as well as those] additional and related duties as may be prescribed by law’ (County Law § 650 [1]), and the Sheriff is prescribed, by law, to safely keep inmates of the County Jail (Correction Law § 500-c), the Sheriff would be bonded against the failure to safely keep plaintiff within the Rensselaer County Jail.” Therefore, the one-year statute of limitations applies, and the action was time-barred because it was not commenced within that period.