H* v. T* centers on two related lawsuits arising from a tragic motorcycle accident in Ulster County, New York, back in July 2017.
KH, operating the motorcycle, and his passenger, CH, allegedly collided with a white van driven by JT. The accident resulted in C*s death, leading to separate but related personal injury suits: one brought by K* himself (Action No. 2), and another by a family member on behalf of the deceased (Action No. 1).
At the core of the dispute is whether T* was responsible in any way for the crash. A crucial development in the pretrial phase was the defendant's reliance on findings from a New York State DMV administrative hearing, where an Administrative Law Judge (ALJ) concluded that K* had caused the accident by speeding, veering into the opposite lane, and ultimately losing control of his motorcycle—without any contact from the van. T* used this ruling to argue that the civil claim should be barred by "collateral estoppel," a doctrine that prevents relitigation of issues already settled in a prior proceeding.
The Orange County Supreme Court agreed and granted summary judgment, effectively dismissing K*’s claim. However, on appeal, the Appellate Division, Second Department, saw the matter differently. While it acknowledged that administrative determinations can carry preclusive weight in civil courts, it found that K* had not been afforded a "full and fair opportunity" to litigate his case during the DMV hearing. Notably, the absence of law enforcement testimony and the denial of cross-examination rights undermined the integrity of the administrative process. Without robust procedural safeguards, the DMV ruling couldn't serve as the "legal end of the road."
More importantly, even apart from collateral estoppel, the AD2 found factual disputes that precluded summary judgment. Although T* presented photos, a sheriff’s report, and his own testimony suggesting his van never touched the motorcycle, K* countered with witness testimony from the DMV transcript indicating the van did cross the double yellow line and strike the bike. That direct contradiction established a classic triable issue of fact. Since New York negligence law recognizes the possibility of multiple proximate causes, it was not for the judge to weigh these competing narratives on summary judgment. That task belongs to a jury.
In the end, the appellate court reversed the dismissal in Action No. 2 and reinstated K*’s claim, underscoring the principle that procedural fairness and fact-finding remain bedrock components of civil justice—even when administrative rulings enter the fray.
Ironically, it looks like the motion court crossed the line here ....
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DECISION