In Palmieri v. Ringling Bros. and Barnum and Bailey Combined Shows Inc. (237 AD2d 589 [2d Dept 1997]) the plaintiff testified that there were three or four steps separating her from her daughter when she was pushed, which suggests that the staircase was not tremendously crowded. The Court also noted that the plaintiff's daughter testified that although people had bumped into her as she was exiting the building, no one had pushed her hard enough for her to lose her balance. Under those circumstances, the Appellate Division concluded that the Supreme Court had "properly found that there is no evidence that the injured plaintiff's freedom of movement was unduly restricted, or that she was unable to find a place of safety." (Id. at 590.)