Russo v. Jay
Plaintiffs Rosemarie Russo and Joseph Ostrowsky sued defendant Kenneth Jay in a small claims action for property damage caused by a tree limb falling from defendant's property. Defendant counterclaimed for trespassing. The Justice Court awarded plaintiffs damages. On appeal, the Appellate Term, Second Department, reversed the judgment, finding that plaintiffs failed to establish a prima facie case by not demonstrating a defective condition or defendant's actual or constructive notice of such a condition in the tree. The court also noted plaintiffs' failure to exercise their right to self-help by pruning overhanging branches. The matter was remitted to the Justice Court for entry of a judgment dismissing the action.