Stevens v. Spec, Inc.
This case involves cross-appeals from an order in Tompkins County regarding an altercation at a nightclub where the plaintiff was struck by defendant John Ryan. The plaintiff sued Spec, Inc. (nightclub owner), Douglas Layaw (Spec's president), and John Ryan for assault, negligence (premises liability), and Dram Shop Act violations. The Supreme Court dismissed the assault claim but allowed the negligence and Dram Shop claims to proceed. On appeal, the court affirmed the dismissal of the assault claim, ruling Ryan was an independent contractor. Furthermore, it reversed the lower court's decision on the negligence and Dram Shop claims, finding the assault was unforeseeable and no commercial alcohol sale occurred, thus granting summary judgment to the defendants on all counts.