Ruffing v. Union Carbide Corp.
The plaintiffs, Candace Curtis and Heather Curtis, appealed two orders from the Supreme Court, Westchester County. The first order denied their motion to amend the complaint to add fraud-based causes of action, and the second denied their motion for leave to reargue. The appellate court dismissed the appeal from the order denying reargument, as such orders are not appealable. However, the court modified the August 3, 2001, order by granting infant plaintiff Candace Curtis leave to assert causes of action for fraudulent misrepresentation, constructive fraud, fraudulent concealment, and negligent misrepresentation. This decision was based on the principle that fraud can exist even when misrepresentations are made to a third party (the mother) but result in injury to the plaintiff (the infant). The court affirmed the denial of the motion to amend for Heather Curtis on statute of limitations grounds related to her negligence claims.