In White v. New York City Housing Authority, 139 A.D.3d 579, 580, 32 N.Y.S.3d 140 (1st Dept 2016), a case wherein the plaintiff's son was burned by a steam heating pipe, the First Department modified the Supreme Court's decision and granted summary judgment dismissing the plaintiff's common law negligence claim. The First Department held that "the mere fact that the heating pipe, a heat source for the bedroom, was hot and lacked insulation, which would have interfered with its function, is not actionable." Id. at 580.