Kobre v. United Jewish Appeal-Federation of Jewish Philanthropies of New York, Inc.
Elisha Kobre, a junior counselor, suffered quadriplegic injuries from a shallow dive at Camp Mogen Avraham in 1991. His mother, Sheryl Kobre, initiated a negligence action against United Jewish Appeal (UJA) and Federation of Jewish Philanthropies of New York Service Corporation (FOJP), alleging they exercised control over the camp's operations and safety. While the action against the camp itself was settled via workers' compensation, UJA and FOJP sought summary judgment, which was initially denied. However, the Appellate Division reversed this decision, finding that neither UJA, a philanthropic funder, nor FOJP, an insurance advisor, exerted sufficient control over the camp's waterfront activities to establish a legal duty of care to the plaintiffs. The court emphasized that FOJP's safety surveys were primarily for its own benefit in reducing insurance risks. Consequently, the defendants' motions for summary judgment were granted, and the complaint was dismissed.