A New York appellate court has issued a significant ruling regarding liability in a slip and fall case that occurred at John F. Kennedy Airport. The decision, made on November 12, 2026, affects several parties, including JetBlue Airways Corporation and OTG JFK T5 Venture, LLC. This ruling is important as it clarifies the responsibilities of businesses operating in shared spaces like airports.

The case, Streppone v. OTG JFK T5 Venture, LLC, was filed under docket number 2024-09468. The plaintiff, Annette Streppone, claimed she sustained injuries after slipping on a wet floor outside the Flo Bar, located in Terminal 5 of JFK Airport. The court's decision will influence how future personal injury claims are handled in similar circumstances.

Background

In this case, Annette Streppone filed a lawsuit against multiple defendants after her fall at JFK Airport. The defendants included OTG JFK T5 Venture, LLC, OTG Management JFK, LLC, OTG Management, LLC, and JetBlue Airways Corporation. The airport terminal is owned by the Port Authority of New York and New Jersey, which leases it to JetBlue. JetBlue, in turn, subleased parts of the terminal to OTG Venture, which operates the Flo Bar.

Both JetBlue and OTG Venture contracted Roma Cleaning, Inc. to provide janitorial services for Terminal 5. In August 2023, JetBlue and the OTG defendants sought summary judgment to dismiss the complaint against them, claiming they were not liable for the incident. Roma also filed a separate motion for summary judgment to dismiss the complaint against it. The Supreme Court of New York initially ruled in favor of JetBlue, dismissing the claims against it, but denied the motions for the other defendants.

The Ruling

The Appellate Division of the Supreme Court of New York reviewed the case and modified the lower court's order. The court ruled that JetBlue did indeed owe a duty of care to Streppone, stating, "The record demonstrated that JetBlue leased terminal 5... and continued to occupy and control terminal 5 even after subleasing certain areas to the OTG defendants." This ruling means that JetBlue cannot escape liability simply because it subleased parts of the terminal.

The court also found that the initial ruling incorrectly dismissed the claims against the OTG defendants. The judges noted that JetBlue and OTG failed to prove they did not have notice of the wet floor prior to the accident. The court emphasized, "Mere reference to general cleaning practices, with no evidence regarding any specific cleaning or inspection of the area in question, is insufficient to establish a lack of constructive notice." This statement underlines the importance of demonstrating proper maintenance to avoid liability.

Impact

This ruling has significant implications for future premises liability cases. It clarifies that businesses cannot simply delegate their responsibilities to contractors and avoid liability for unsafe conditions on their property. The court's decision reinforces that if a business occupies and controls a space, it must ensure that it is safe for patrons.

Moreover, the ruling sets a precedent for how courts will interpret duty of care in similar situations. Businesses operating in shared spaces, like airports or malls, must be diligent in maintaining safe conditions, as they can be held liable for injuries that occur on their premises. This ruling could lead to increased scrutiny of cleaning and maintenance practices in such environments.

What's Next

The case may still have further developments, as the parties involved could seek to appeal the ruling. Details regarding any potential appeal or related cases were not available in the court filing. However, the decision has already set a clear standard for liability in personal injury cases involving shared commercial spaces.