Scholastic Inc. v. Pace Plumbing Corp.
Plaintiff, Scholastic Inc., suffered over $1.5 million in water damage in 2006 due to a broken Victaulic coupling in its Manhattan building, installed by defendant Pace Plumbing Corp. Scholastic's insurer, subrogated to its rights, sued Pace in 2008 for negligence and breach of contract. Pace's answer included a single paragraph listing 16 boilerplate affirmative defenses, including the statute of limitations, without separate numbering. The motion court deemed the statute of limitations defense inadequately pleaded but granted summary judgment to Pace on the merits. The appellate court reversed, holding that Pace's statute of limitations defense was indeed inadequately pleaded and prejudiced Scholastic by hindering targeted discovery. The case was remanded to allow Pace to amend its pleading and Scholastic to conduct discovery on the statute of limitations issue, specifically the completion date of Pace's work. The court also raised questions regarding the universal applicability of prior precedent on pleading particularity compared to Official Form 17.