Nonnon v. City of New York

In Nonnon v. City of New York (32 AD3d 91, 819 NYS2d 705 [1st Dept 2006]) the court conceded that epidemiological studies were not novel and hence did not require Frye analysis. The court defined epidemiology as "a science which focuses on the question of general causation (i.e., is the [landfill] capable of causing disease?) rather than that of specific causation (i.e., did [the landfill] cause disease in a particular individual?)" (id. at 112, 819 NYS2d 705). Thus, "this field of science is the primary generally accepted methodology for demonstrating a causal relation between a chemical compound and a set of symptoms or a disease" (id. at 104, 819 NYS2d 705). The court found that the experts engaged in standard scientific procedure and methodology and reached acceptable conclusions. Therefore, the court permitted expert evidence linking carcinogens found at a landfill causing injuries to plaintiffs.