Hilowitz v. Hilowitz
In a negligence action for personal injuries, the plaintiff appealed an order from the Supreme Court, Queens County, dated October 22, 1980. The order, issued by Justice Hyman, had denied the plaintiff's motion to dismiss the defense of collateral estoppel. The appellate court affirmed the order, holding that an arbitration award, even without judicial confirmation, can serve as a basis for res judicata and collateral estoppel if there was a final determination on the merits. The court referenced Kilduff v Donna Oil Corp. and distinguished Hana Heating & Air Conditioning Co. v Sheet Metal Workers Int. Assn. All other contentions raised by the plaintiff were deemed to be without merit.