Jenkins v. Dewitt Rehabilitation & Nursing Ctr. Inc.

2025 NY Slip Op 32250(U)
CourtNew York Supreme Court, New York County
DecidedJune 24, 2025
DocketIndex No. 153230/2022
StatusUnpublished

This text of 2025 NY Slip Op 32250(U) (Jenkins v. Dewitt Rehabilitation & Nursing Ctr. Inc.) is published on Counsel Stack Legal Research, covering New York Supreme Court, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jenkins v. Dewitt Rehabilitation & Nursing Ctr. Inc., 2025 NY Slip Op 32250(U) (N.Y. Super. Ct. 2025).

Opinion

Jenkins v Dewitt Rehabilitation & Nursing Ctr. Inc. 2025 NY Slip Op 32250(U) June 24, 2025 Supreme Court, New York County Docket Number: Index No. 153230/2022 Judge: John J. Kelley Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. FILED: NEW YORK COUNTY CLERK 06/24/2025 04:47 PM INDEX NO. 153230/2022 NYSCEF DOC. NO. 94 RECEIVED NYSCEF: 06/24/2025

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. JOHN J. KELLEY PART 56M Justice ---------------------------------------------------------------------------------X INDEX NO. 153230/2022 LEOVA JENKINS, as Proposed Administrator of the Estate of ELOISE BROOKS, MOTION DATE 04/25/2025

Plaintiff(s), MOTION SEQ. NO. 001

-v- DEWITT REHABILITATION AND NURSING CENTER INC. d/b/a UPPER EAST SIDE REHABILITATION AND DECISION + ORDER ON NURSING CENTER, ABC CORPORATION, ABC MOTION PARTNERSHIP,

Defendant(s). ---------------------------------------------------------------------------------X

The following e-filed documents, listed by NYSCEF document number (Motion 001) 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55, 56, 57, 58, 59, 60, 61, 62, 63, 64, 65, 66, 67, 68, 69, 70, 71, 72, 73, 74, 75, 76, 77, 78, 79, 80, 81, 82, 83, 84, 85, 86, 87, 88, 89, 90, 91, 92, 93. were read on this motion to/for DISMISS .

In this action to recover damages, inter alia, for medical malpractice, and pursuant to

Public Health Law §§ 2801-d and 2803-c for purported violations of statutes and regulations

governing nursing homes, the defendant Dewitt Rehabilitation and Nursing Center, Inc., doing

business as Upper East Side Rehabilitation and Nursing (Dewitt), moves pursuant to CPLR

3211(a) to dismiss the complaint as against it on the ground that the complaint fails to state a

cause of action (CPLR 3211[a][7]) and for lack of subject matter jurisdiction (CPLR 3211[a][2]).

The plaintiff opposes the motion. The motion is granted only to the extent that claims asserting

that Dewitt engaged in acts or omissions constituting malpractice or statutory nursing home

negligence between March 7, 2020 and April 6, 2021 are dismissed, inasmuch as the complaint

fails to state a cause of action against it by virtue of the immunity from civil liability conferred

upon it by the Emergency or Disaster Treatment Protection Act (Public Health Law former §§

3080–3082; hereinafter EDTPA). The motion is otherwise denied, however, as to the

153230/2022 LEOVA JENKINS, as Administrator of the Estate of ELOISE BROOKS vs. DEWITT Page 1 of 11 REHABILITATION and NURSING CENTER INC. Motion No. 001

1 of 11 [* 1] FILED: NEW YORK COUNTY CLERK 06/24/2025 04:47 PM INDEX NO. 153230/2022 NYSCEF DOC. NO. 94 RECEIVED NYSCEF: 06/24/2025

allegations arising from the care that the plaintiff’s decedent, Eloise Brooks (the decedent),

received at Dewitt prior to the effective date of EDTPA, since the court concludes that the

plaintiff has sufficiently alleged causes of action that fall outside the scope of EDTPA immunity.

The decedent was a resident of Dewitt from approximately November 2019, until she

was transferred to Lenox Hill Hospital (Lenox Hill) on April 8, 2020. She died on April 14, 2020.

In the complaint, the plaintiff, Leova Jenkins, as administrator of the decedent’s estate, alleged

that Dewitt became aware of the COVID-19 pandemic in or around January 2020, but failed to

provide the decedent with appropriate care or customary nursing and rehabilitation services

between January 2020 and the decedent’s April 8, 2020 transfer to Lenox Hill. The plaintiff

further alleged that the decedent contracted COVID-19 while at Dewitt’s facility, and that Dewitt

failed to take proper precautions to prevent and control the spread of infections, including by

failing to provide adequate personal protective equipment (PPE), failing to isolate infected

residents, inadequately sanitizing equipment, and failing to screen staff and visitors for COVID-

19 symptoms. Finally, the plaintiff alleged that the decedent suffered from neglect and the

deterioration of her condition as a result of the facility’s failures during the COVID-19 crisis.

In its motion, Dewitt argued that the court lacked subject matter jurisdiction over this

action, and that the complaint should be dismissed for failure to state a cause of action because

EDTPA and Executive Order 202.10 conferred immunity upon it from civil actions such as the

instant case. Dewitt further contended that the federal Public Readiness and Emergency

Preparedness Act (Pub. L. 109-148, as amended, Pub. L. 116-127, 42 USC § 247d-6d;

hereinafter the PREP Act) also provided it with immunity for acts related to healthcare services

and “covered countermeasures” undertaken in response to the COVID-19 pandemic. The

plaintiff, in opposition, argued that the court has subject matter jurisdiction and that, in any

event, EDTPA immunity is inapplicable because the statute has since been repealed, and that

the care provided to the decedent was a continuation of services that began prior to the

pandemic. The plaintiff further contended that the PREP Act does not apply, as the claims do 153230/2022 LEOVA JENKINS, as Administrator of the Estate of ELOISE BROOKS vs. DEWITT Page 2 of 11 REHABILITATION and NURSING CENTER INC. Motion No. 001

2 of 11 [* 2] FILED: NEW YORK COUNTY CLERK 06/24/2025 04:47 PM INDEX NO. 153230/2022 NYSCEF DOC. NO. 94 RECEIVED NYSCEF: 06/24/2025

not involve the use or implementation of any covered countermeasures. Finally, the plaintiff

argued that the complaint sufficiently alleged gross negligence and recklessness, which fall

outside the scope of statutory immunity under both EDTPA and the PREP Act.

When assessing the adequacy of a pleading in the context of a motion to dismiss under

CPLR 3211(a)(7), the court’s role is “to determine whether [the] pleadings state a cause of

action” (511 W. 232nd Owners Corp. v Jennifer Realty Co., 98 NY2d 144, 151-152 [2002]). To

determine whether a claim adequately states a cause of action, the court must “liberally

construe” it, accept the facts alleged in it as true, accord it “the benefit of every possible

favorable inference” (id. at 152; see Romanello v Intesa Sanpaolo, S.p.A., 22 NY3d 881 [2013];

Simkin v Blank, 19 NY3d 46 [2012]), and determine only whether the facts, as alleged, fit within

any cognizable legal theory (see Taxi Tours, Inc. v Go New York Tours, Inc., 41 NY3d 991, 993

[2024]; Hurrell-Harring v State of New York, 15 NY3d 8 [2010]; Leon v Martinez, 84 NY2d 83

[1994]; Weil, Gotshal & Manges, LLP v Fashion Boutique of Short Hills, Inc., 10 AD3d 267 [1st

Dept 2004]; CPLR 3026). “The motion must be denied if from the pleading's four corners factual

allegations are discerned which taken together manifest any cause of action cognizable at law”

(511 W. 232nd Owners Corp. v Jennifer Realty Co., 98 NY2d at 152 [internal quotation marks

omitted]; see Leon v Martinez, 84 NY2d at 87-88; Guggenheimer v Ginzburg, 43 NY2d 268

[1977]). Where, however, the court considers evidentiary material beyond the complaint, as it

does here, the criterion becomes “whether the proponent of the pleading has a cause of action,

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2025 NY Slip Op 32250(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/jenkins-v-dewitt-rehabilitation-nursing-ctr-inc-nysupctnewyork-2025.