Streit v. Katrine Apts. Assoc., Inc.
Phyllis Streit was injured after tripping over partially obstructed chicken wire on property owned by Katrine Apts. Associates, Inc., resulting in a three-part proximal humerus fracture requiring two surgeries. She commenced a negligence action, and a jury found defendant 70% at fault, awarding $750,000 in damages. Defendant appealed, contesting legal sufficiency of evidence regarding property control and notice, and the excessiveness of damages. The Appellate Division, Third Department, affirmed the judgment and order, finding sufficient evidence for the jury's conclusions on control and constructive notice, and that the damages awarded were reasonable given the severity and permanency of plaintiff's injuries. The court also clarified that the open and obvious nature of a hazard impacts fault apportionment but not the duty to maintain safe premises.