DiVetri v. ABM Janitorial Service, Inc.
Anna DiVetri slipped and fell on a wet marble lobby floor after tracking in water from an adjacent sidewalk being cleaned by ABM Janitorial Service, Inc. She sustained injuries and filed a complaint. The defendants, including the building owner, managing agent, and cleaning contractor, moved for summary judgment to dismiss the complaint, which was denied by the Supreme Court. On appeal, the Appellate Division, First Department, unanimously affirmed the lower court's decision. The court found genuine issues of fact existed regarding whether the defendants created a dangerous condition by failing to take precautions against tracked-in water during sidewalk cleaning. Furthermore, it ruled that ABM, as an outside contractor, could owe a duty of care to the plaintiff despite the lack of a direct contract, under the "force or instrument of harm" exception.