Aldrich v. State of New York

Owners of property situated along a road in Caroline, New York (plaintiffs) filed two separate actions against the State of New York (State) (defendant), alleging that the State’s negligent design and construction of a nearby bridge resulted in damages from flooding that occurred on July 11, 1976. Before those cases went to trial, the plaintiffs filed another set of suits against the State in which they again asserted that the State’s negligence related to the bridge had caused personal injury and property damages from flooding that occurred on October 28, 1981. In April 1983, a four-day trial was held on the first set of cases in which both sides presented expert testimony. At the trial’s conclusion, the Court of Claims held that the damages suffered by the plaintiffs were caused by an act of God and, in any event, that the bridge conformed to good engineering practice, precluding a negligence claim against the State. The court was persuaded by State witnesses who testified that the bridge design was proper under relevant standards, which did not require considering the effects of a storm so severe that it was expected to recur less than once per century. The plaintiffs did not appeal. The State then moved for partial summary judgment in the second set of cases as to the issue of negligent design and construction of the bridge. Following the Restatement (Second) of Judgments, the court denied the State’s motion, concluding that the prior court’s determination on negligence was not necessary to the earlier judgment. The State appealed.