Battista v. American Institute for Mental Studies

In Battista v. American Institute for Mental Studies (183 AD2d 416 [1st Dept 1992]), plaintiffs sued for personal injuries suffered by the infant plaintiff who had been placed into foster care with the Commissioner of Social Services of the City of New York (the "City"). The City placed the child with the defendant American Institute for Mental Studies ("AIMS"), at its Vineland, New Jersey facility. The plaintiffs alleged that due to the City's failure to supervise the placement of the child and because of their failure to provide proper medical treatment, the infant plaintiff suffered physical injuries. In deciding whether AIMS was subject to New York jurisdiction, the Court noted that AIMS entered into a contract with the City to care for the infant plaintiff and other children. The City paid AIMS approximately $ 45,000 a year for each child housed at its facility. Pursuant to the contract, AIMS submitted bills for payment, vouchers for expenditures and reports to the City regarding the care provided each child. AIMS agreed to follow City guidelines for the care of the children and further agreed to report all accidents and injuries suffered by a child to the City. AIMS also employed a New York insurance broker to obtain the insurance required by the contract. Citing to CPLR 302(a)(1), the Court held that "AIMS' contacts with New York were purposeful and that there was a substantial relationship between its transactions in New York and the claim asserted. The Court also held that since "AIMS availed itself of the benefits of this jurisdiction, had sufficient minimum contacts here and should have reasonably expected to defend its actions in New York, due process is not offended by subjecting it to the jurisdiction of the New York courts.