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Court of Appeals of New York


METLIFE AUTO & HOME v. JOE BASIL CHEVROLET, INC., 5

New York does not recognize a cause of action for third-party negligent spoliation of evidence and impairment of a claim or defense as an independent tort. The burden of forcing a party to preserve when it has no notice of an impending lawsuit, and the difficulty of assessing damages, militate against establishing such a cause of action here, where there is no duty, court order, contract or special relationship.

Appellate Information

  • Decided 02/24/2004
  • Published 02/24/2004

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  • Court of Appeals of New York

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