Spina v. Browning Hotel Props., LLC
The plaintiff, Kaitlyn Spina, appealed an order from the Supreme Court, Suffolk County, which granted the defendants' motion to dismiss her complaint and denied her cross-motion for leave to amend. Spina sought damages for negligent hiring, retention, and supervision after allegedly being sexually assaulted by a hotel employee at a property owned and operated by the defendants, Browning Hotel Properties, LLC. The Appellate Division, Second Department, reversed the lower court's decision, finding that the Supreme Court improvidently exercised its discretion in denying Spina's cross-motion to amend, as the proposed amendments were not palpably insufficient. Furthermore, the Court determined that the Supreme Court erred in granting the defendants' motion to dismiss, as the proposed amended complaint sufficiently pleaded causes of action for negligent hiring, retention, and supervision. The order was reversed, the defendant's motion to dismiss was denied, and the plaintiff's cross-motion for leave to amend was granted.