A New York appellate court has reversed a lower court's decision that dismissed a personal injury lawsuit stemming from a vehicle collision. The ruling affects plaintiff Jessica Pruessen, who was involved in an accident with a vehicle owned by Richard Capobianco, Inc. The case highlights the importance of evidence in personal injury trials and the rights of plaintiffs to have their cases heard by a jury.

The Appellate Division of the Supreme Court of the State of New York issued its decision on October 21, 2026, in the case of Pruessen v. Richard Capobianco, Inc. (Docket No. 2025-02836). The court's ruling allows Pruessen's complaint to proceed to a new trial after the initial trial court dismissed her case.

Background

The dispute began on August 7, 2020, when a vehicle operated by Andrew Capobianco, an employee of Richard Capobianco, Inc., collided with Pruessen's vehicle at an intersection in Huntington, New York. At the time of the accident, First Street was controlled by a stop sign while Fourth Avenue had no traffic control devices. Pruessen claimed she had stopped at the intersection and proceeded only when it was safe, while Capobianco testified that he saw her vehicle just moments before the collision.

The case was brought to trial, where Pruessen sought to recover damages for the injuries she sustained in the accident. However, during the trial, the Supreme Court of Suffolk County excluded critical evidence—three photographs showing the damage to both vehicles. This decision played a significant role in the trial's outcome, as the court later granted the defendants' motion for judgment as a matter of law, effectively dismissing Pruessen's complaint.

The Ruling

The appellate court ruled that the lower court made an error by dismissing Pruessen's case. The court stated that the defendants did not meet the burden required to justify a judgment as a matter of law. The opinion noted, "To be entitled to judgment as a matter of law... a moving defendant has the burden of showing that there is no rational process by which the jury could find in favor of the plaintiff."

The judges emphasized that the trial court should have considered the evidence in the light most favorable to Pruessen. They found that there was a rational basis for a jury to determine that Capobianco failed to exercise reasonable care, even if he had the right-of-way. The court also criticized the exclusion of the photographs, stating that they were relevant to the issue of liability and could have impacted the jury's decision.

The court concluded, "Accordingly, the Supreme Court should have denied the defendants' motion... dismissing the complaint." As a result, the appellate court reinstated Pruessen's complaint and ordered a new trial.

Impact

This ruling is significant for personal injury cases in New York, as it underscores the importance of allowing juries to consider all relevant evidence. The decision reinforces the principle that a plaintiff's case should not be dismissed without a thorough examination of the facts and circumstances surrounding the incident.

The reinstatement of Pruessen's case means that she will have the opportunity to present her evidence and arguments to a jury, which could lead to a different outcome than the initial trial. This ruling may also encourage other plaintiffs in similar situations to pursue their claims, knowing that they have the right to have their cases heard fairly.

What's Next

Pruessen's case will now return to the Supreme Court of Suffolk County for a new trial. The defendants may still have the option to appeal the appellate court's decision, but details about any potential appeal were not available in the court filing. The outcome of the new trial will depend on the presentation of evidence and the jury's assessment of liability.