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Langan v. St. Vincent’s Hospital of New York

Supreme Court of New York, Appellate Division
802 N.Y.S.2d 476 (2005)


Facts

Neil Conrad Spicehandler and John Langan (plaintiff) lived in New York as a monogamous, same-sex couple. In 2000, when same-sex marriage was not yet legal in New York, they entered into a civil union in Vermont, then returned to New York. In 2002, Spicehandler was hit by a car. He was treated for his injuries at St. Vincent’s Hospital of New York (St. Vincent’s) (defendant) but died from his injuries. New York’s wrongful-death statute provided that surviving spouses could be compensated for the loss of expected income caused by a person’s wrongful death. Langan brought a wrongful-death action against St. Vincent’s. St. Vincent’s moved to dismiss the suit, arguing that Langan had no standing as a surviving spouse because he and Spicehandler were not married. The trial court denied the motion. St. Vincent’s appealed the court’s order.

Rule of Law

Issue

Holding and Reasoning (Lifson, J.)

Dissent (Fisher, J.)

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