Stevens v. Spec, Inc

In Stevens v. Spec, Inc., 224 A.D.2d 811 (3rd Dept 1996), the Third Department determined that a nightclub owner was not liable for injuries sustained by one of its patrons when he was hit with a bottle by a non employee, independent contractor. The assault took place when plaintiff refused to the leave the stage area after a performance and the total altercation lasted 20 to 30 seconds.