Cornell v. 360 West 51st Street Realty, LLC
Brenda Cornell sued 360 West 51st Street Corp. for personal injuries allegedly caused by indoor exposure to dampness and mold in her Manhattan apartment. The Supreme Court initially granted summary judgment to the defendant, finding Cornell failed to prove general or specific causation under the Frye standard. The Appellate Division subsequently reversed this, suggesting Cornell's expert opinion had "some support" in scientific literature. However, the Court of Appeals, in this opinion, reversed the Appellate Division's decision, concluding that Cornell failed to raise a triable issue of fact. The court reiterated that scientific "association" does not equate to "causation" and found her expert's differential diagnosis insufficient due to lack of exposure quantification and inadequate ruling out of other causes. Consequently, the defendant's motion for summary judgment dismissing the complaint was ultimately granted.