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The case of Smith-Percival v MTA Bus Co., 2024 NY Slip Op 06000, focused on whether certain discovery requests should be enforced in a personal injury lawsuit. While the claim centered on an injury suffered by a passenger, the legal issue before the Appellate Division, Second Department, was about the production of GPS and route records. These documents could provide facts needed to prepare for trial and determine whether the defendants contributed to the plaintiff’s injuries. The court’s ruling addressed what information must be shared and how far a defendant must go to comply with discovery in a personal injury case involving public transportation.
Background Facts
On December 22, 2017, Merlene Smith-Percival was riding on a bus operated by the MTA Bus Company when the bus came into contact with a vehicle belonging to the New York City Police Department. Smith-Percival claimed that she was injured during the incident.
In October 2018, she filed a lawsuit in Kings County Supreme Court seeking damages for those injuries. She named as defendants the MTA Bus Company, the New York City Transit Authority, and the Metropolitan Transportation Authority. During the litigation, Smith-Percival asked the defendants to provide certain documents, including GPS records and the route schedule for the bus involved in the crash.
The defendants objected to producing those records. As a result, the plaintiff filed a motion asking the court to compel the defendants to turn over the GPS and bus route information. On March 2, 2023, the trial court granted the plaintiff’s request. The defendants then appealed to the Appellate Division, Second Department.
Question Before the Court
The issue before the appellate court was whether the Supreme Court correctly ordered the MTA Bus Company and related defendants to turn over GPS and route data. The court had to decide if the discovery request was appropriate under CPLR 3101(a), which requires parties to share information that is material and necessary to the prosecution or defense of a case.
Court’s Decision
The Appellate Division, Second Department, affirmed the lower court’s ruling. The appellate court held that the trial judge properly exercised discretion in requiring the defendants to comply with the discovery request.
The court pointed out that under CPLR 3101(a), parties are required to provide full disclosure of all facts that are material and necessary to the preparation of a case. The court interpreted this standard to allow for the disclosure of any facts that could help sharpen the legal issues or reduce trial delays.
The court noted that even though a party is not entitled to unlimited discovery, the plaintiff had shown a valid reason to request the GPS and route documents. According to the court, the records could reveal facts about the timing and location of the bus, which might help prove whether the bus was in the position the plaintiff claimed and whether that position contributed to her injuries.
Discussion
The court explained that discovery requests must be tied to the claims in the case. A party must show that the information sought could reasonably lead to evidence relevant to the case. Bare statements that something “might be helpful” are not enough. Instead, there must be a logical link between the records requested and the claim being made.
In this case, Smith-Percival claimed that GPS and route records would provide evidence about the “place, proximity, and timing” of the bus when it struck the police vehicle. She argued that this information would help determine whether the bus contributed to the accident and her injuries. The appellate court agreed that this connection was clear enough to justify the request.
The decision also reaffirmed that trial courts have wide discretion when managing discovery. As long as a court’s decision is reasonable and tied to the facts of the case, appellate courts will generally not reverse it. Here, the Supreme Court weighed the facts and concluded that the GPS and route data were relevant and should be produced. The Appellate Division saw no reason to disturb that decision.
Conclusion
The court’s ruling in Smith-Percival v MTA Bus Co. supported a passenger’s right to access key documents in a personal injury lawsuit against a public transit agency. The case showed that when a party makes a request for documents that are tied to a specific claim, the court is likely to order those records to be produced.
This decision also confirmed that discovery rules under New York law require cooperation and transparency when parties seek information that may help explain how an accident occurred. While the case involved a legal dispute over documents, it served as part of a larger effort by the plaintiff to prove her claims and hold the defendants accountable.
If you or a loved one were injured in a bus accident in New York and have questions about your legal rights, contact an experienced New York bus accident lawyer at Stephen Bilkis & Associates to discuss your options.