Nellenback v. Madison County
Michael Nellenback sued Madison County under the Child Victims Act for negligent supervision after being sexually abused by his social services caseworker, Karl Hoch, between 1993 and 1996. Nellenback alleged the County was negligent in hiring, supervising, and retaining Hoch, who was later convicted of abusing other children. The Supreme Court granted summary judgment to the County, which the Appellate Division affirmed, finding no triable issue of fact on the negligent supervision claim. The Court of Appeals affirmed, holding that Nellenback failed to prove the County had actual or constructive notice of Hoch's propensities or that lax supervision would have revealed the abuse, and that evidence for this was purely speculative. The dissenting opinion argued that there were triable issues of fact regarding the County's lax supervision and its failure to identify warning signs.