Civil Rights

Busch v. County of Erie — Federal Hepatitis A Findings Bar State Jail Conditions Claim Via Collateral Estoppel

/ June 28, 2026

The Fourth Department bars a state premises-liability claim arising from hepatitis A contraction in Erie County jail under collateral estoppel, based on the federal court’s explicit finding that the plaintiff produced no evidence of unsanitary conditions, and dismisses punitive damages against the municipality.

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Busch v. County of Erie — Federal Hepatitis A Findings Bar State Jail Conditions Claim Via Collateral Estoppel