Bryan Scurry v. New York City Housing Authority, Estate of Tayshana Murphy v. New York City Housing Authority

Summary

The court held that a landlord's failure to provide functioning exterior door locks may be a proximate cause of injuries from targeted criminal attacks, and that the attackers' intent does not sever causation as a matter of law. Because the plaintiffs raised triable issues concerning whether functioning locks would have deterred or delayed the attacks, summary judgment was improper in both cases. The court affirmed the denial of summary judgment in Scurry and reversed the grant of summary judgment in Murphy, requiring both negligence claims to proceed to trial.