Garrett v. Holiday Inns

In Garrett v. Holiday Inns (58 NY2d 253) the Court of Appeals explained that "if an independent obligation can be found on the part of a concurrent wrongdoer to prevent foreseeable harm, he [or she] should be held responsible for the portion of the damage attributable to his or her negligence, despite the fact that the duty violated was not one owing directly to the injured person" (id. at 261). In other words, "a party seeking contribution must show that the co-defendant from whom contribution is sought owes a duty either to him or to the injured party and that a breach of this duty has contributed to the alleged injuries"