In a recent ruling, the Appellate Division of the Supreme Court of the State of New York dismissed a wrongful death lawsuit against John E. Andrus Memorial, Inc., a nursing home. The court's decision, made on October 7, 2026, affects the family of Joann Rodriguez-Williams, who filed the lawsuit after her relative died from COVID-19 complications while residing at the facility. This case highlights the legal protections that nursing homes may have under specific public health laws during the pandemic.
The lawsuit, filed under docket number 2024-08795, alleged that the nursing home was negligent in its care, leading to the infection and subsequent death of the resident on April 28, 2020. The ruling is significant as it reinforces the legal immunity granted to healthcare facilities during the COVID-19 pandemic, potentially impacting similar cases across the state.
Joann Rodriguez-Williams, as the administrator of the estate of the deceased, initiated the action against the nursing home, claiming that the facility's failure to protect residents from COVID-19 led to her relative's death. The complaint included allegations of negligence, gross negligence, and violations of Public Health Law § 2801-d. The case was brought to the Appellate Division after the Supreme Court of Westchester County dismissed the complaint in July 2024.
The dispute arose when the nursing home filed a motion to dismiss the lawsuit, arguing that it was protected under the Emergency or Disaster Treatment Protection Act (EDTPA). This law provided immunity to healthcare facilities from civil liability for harm caused during the COVID-19 pandemic, as long as certain conditions were met. The nursing home contended that it acted in good faith and followed state directives during the health crisis.
The Supreme Court agreed with the nursing home's argument and granted the motion to dismiss the complaint. Rodriguez-Williams then appealed the decision, seeking to have the ruling overturned.
In its ruling, the Appellate Division upheld the lower court's decision, affirming that the nursing home was entitled to immunity under the EDTPA. The court stated, "The defendant's submissions in support of its motion... conclusively established that the defendant was entitled to immunity, as the three requirements for immunity under the EDTPA were satisfied." The judges on the panel included Colleen D. Duffy, Barry E. Warhit, Lourdes M. Ventura, and Lisa S. Ottley.
The court emphasized that the nursing home met the criteria for immunity, which included providing services in response to the COVID-19 emergency and acting in good faith. The ruling noted that the plaintiff's allegations of gross negligence lacked factual specificity and were insufficient to survive a motion to dismiss.
This decision is crucial as it sets a precedent for how similar cases may be handled in the future. It underscores the legal protections that nursing homes and other healthcare facilities can invoke in response to lawsuits related to COVID-19. Families seeking to hold such facilities accountable may find it challenging to overcome these legal barriers.
The ruling also highlights the ongoing legal implications of the pandemic on healthcare facilities. As many nursing homes and hospitals face lawsuits related to their handling of COVID-19, this case serves as a reminder of the protections afforded to them under state law. The outcome may influence how future claims against healthcare providers are approached, particularly those involving allegations of negligence during public health emergencies.
Looking ahead, the plaintiff has the option to appeal the decision to a higher court. However, details regarding any potential appeal or related cases were not available in the court filing. The outcome of this case may have lasting effects on the legal landscape surrounding nursing home liability and public health law in New York.