DSB was successful in moving to dismiss a claim against an individual defendant in New York State. Plaintiff was allegedly injured during the course of an African hair braiding procedure when her scalp was scalded with hot water. The defendant, the sister of the owner of the salon, was found to owe no duty to the plaintiff as she did not own, operate, manage or control the salon where the incident occurred. Defendant’s only nexus to the salon was the collection of rent from the independent stylists working there while her sister was away. The Court further determined that even if the defendant was found to be an operator of the salon, she still could not be held liable in her individual capacity for the negligent acts of an independent stylist.