Santana v. New York City Housing Authority

Order, Supreme Court, New York County (George J. Silver, J.), entered March 5, 2014, which granted defendant New York City Housing Authority’s (NYCHA) motion for summary judgment dismissing the complaint, unanimously affirmed, without costs.

The award of summary judgment to NYCHA was proper based on the storm in progress doctrine. The parties’ expert meteorologists both opined that the icy condition of the ramp on which plaintiff fell was the result of overnight snow that did not end until 6:03 a.m., about 82 minutes before the accident occurred at 7:25 a.m. on January 2, 2010, when a holiday…