Calabrese v. City of Albany

Summary

The Court affirmed the Appellate Division, holding that electronic reports submitted through the City’s SeeClickFix system satisfy the statutory “written notice” requirement and were actually given to the Commissioner of General Services, and that the City is not immune from liability for its proprietary road‑repair functions. The decision rests on a plain‑meaning construction of “written” and on precedent that notice to a subordinate can satisfy the notice statute.