Sammis v. Nassau/Suffolk Football League, 95 N.Y.2d 809 (2000)

The doctrine of assumption of risk does not automatically relieve a defendant of their duty of care; comparative fault principles may apply, requiring a fact-finder to assess the relative culpability of all parties involved.

Summary

Edwin Sammis sustained injuries while assisting Alex Caruana in removing a box from an elevated shelf. Sammis sued the Nassau/Suffolk Football League and others, alleging negligence. The lower courts granted summary judgment to the defendants, reasoning that Sammis had assumed the risk of injury by helping Caruana. The Court of Appeals reversed, holding that the lower courts erred in concluding that Sammis’s actions relieved the defendants of their duty of care. The Court of Appeals found that there were issues of fact as to comparative fault, and the case should be decided by a fact finder.

Facts

Edwin Sammis assisted Alex Caruana in removing a box from an elevated shelf in an equipment shed at the North Babylon Athletic Club.

During the process, Sammis sustained injuries.

Sammis and his wife sued the Nassau/Suffolk Football League and other related parties (excluding the Town of Babylon), alleging negligence.

Procedural History

The plaintiffs moved for partial summary judgment on the issue of liability.

Supreme Court denied the plaintiffs’ motion and, *sua sponte*, granted summary judgment to the defendants, dismissing the complaint based on the doctrine of assumption of risk.

The Appellate Division affirmed the Supreme Court’s decision.

The New York Court of Appeals reversed, modifying the Appellate Division’s order by denying summary judgment to defendants.

Issue(s)

Whether a plaintiff’s act of helping another person remove an object from an elevated shelf automatically relieves the defendants of their duty of care, thereby entitling them to summary judgment.

Holding

No, because comparative fault principles apply, requiring a fact-finder to assess the relative culpability of all parties involved.

Court’s Reasoning

The Court of Appeals held that the lower courts erred in concluding that Sammis’s act of helping Caruana remove the box relieved the defendants of any duty of care or otherwise established the defendants’ entitlement to summary judgment. The Court clarified that assumption of risk does not automatically negate a defendant’s duty.

The Court reasoned that issues of fact existed regarding comparative fault. CPLR 1411 dictates consideration of comparative fault.

The Court emphasized that the record did not provide a basis for granting the plaintiffs partial summary judgment on the question of the defendants’ liability, either. It was a matter for the jury.