New York Case Commentaries

FOIL § 87(2)(f) Permits Withholding a Statewide Certified-Officer Registry Where Cross-Referencing Public Payroll Data Could Identify Undercover Officers

Date: Apr 3, 2026

FOIL § 87(2)(f) Permits Withholding a Statewide Certified-Officer Registry Where Cross-Referencing Public Payroll Data Could Identify Undercover Officers 1. Introduction Matter of Munson v New York...

People v. Bowden: Speculative Surveillance “Handoff” and Unproven Firearm Operability Cannot Sustain Accomplice or Weapon Convictions

Date: Apr 3, 2026

Speculative Surveillance “Handoff” and Unproven Firearm Operability Cannot Sustain Accomplice or Weapon Convictions (People v. Bowden) 1. Introduction People v Bowden (2026 NY Slip Op 02003 [248 AD3d...

DNA on Vulvar Swabs as “Access” Evidence (Not Molineux) and Curability of Noncustodial “Need a Lawyer” Testimony — People v. Oquendo

Date: Apr 3, 2026

DNA on Vulvar Swabs as “Access” Evidence (Not Molineux) and Curability of Noncustodial “Need a Lawyer” Testimony — People v Oquendo 248 AD3d 1325 (3d Dept Apr. 2, 2026) (published) — affirming...

Change in Circumstances Standard on a Motion to Dismiss in Custody Modification: Expanded Parenting Availability Alone Can Suffice

Date: Apr 3, 2026

Change in Circumstances Standard on a Motion to Dismiss in Custody Modification: Expanded Parenting Availability Alone Can Suffice Introduction Matter of Joshua X. v Alexandria Y. (Appellate...

Equitable Tolling of Foreclosure Interest for Plaintiff-Caused Standing Delay: Tolling from the First Defective Standing Motion

Date: Apr 2, 2026

Equitable Tolling of Foreclosure Interest for Plaintiff-Caused Standing Delay: Tolling from the First Defective Standing Motion Introduction HSBC Bank USA, N.A. v Ehrenthal (2026 NY Slip Op 01949...

License-Plate-Reader Robbery Hit Justifies Level-Three Stop; Plain-View Gun Creates Probable Cause and Exigency for Warrantless Search of a Worn Fanny Pack Incident to Arrest

Date: Apr 2, 2026

License-Plate-Reader Robbery Hit Justifies Level-Three Stop; Plain-View Gun Creates Probable Cause and Exigency for Warrantless Search of a Worn Fanny Pack Incident to Arrest Case: People v David,...

Lin Chen v Zum Dev., Inc.: Contract Disclaimers and Caveat Emptor Bar Fraud/Quasi-Contract Claims in Arm’s-Length Home Sales; Liberal Vacatur of Short, Nonwillful Defaults

Date: Apr 2, 2026

Contract Disclaimers and Caveat Emptor Bar Fraud and Quasi-Contract Claims in Arm’s-Length Home Sales; Short, Nonwillful Defaults Should Be Vacated When Meritorious Defenses Exist 1. Introduction In...

Estrella v. BMG Monroe I, LLC — Makeshift Passageways Are Not “Safety Devices” Under Labor Law § 240(1) and Unconstructed Planks/Adjacent Trenches Often Fall Outside Industrial Code “Runway/Ramp” and “Hazardous Opening” Rules

Date: Apr 2, 2026

Makeshift Passageways Are Not “Safety Devices” Under Labor Law § 240(1) and Unconstructed Planks/Adjacent Trenches Often Fall Outside Industrial Code “Runway/Ramp” and “Hazardous Opening” Rules...

Wilber v. Borgen: No Expert-Affidavit Prerequisite on a CPLR 3211(a)(7) Motion (Absent CPLR 3211(c) Conversion)

Date: Apr 2, 2026

Wilber v. Borgen: No Expert-Affidavit Prerequisite on a CPLR 3211(a)(7) Motion (Absent CPLR 3211(c) Conversion) 1. Introduction Case: Wilber v Borgen, 2026 NY Slip Op 02001 (App. Div. 2d Dep’t Apr....

Ignatiadis v. Shorefront: Conclusory Expert Affidavits and Newly Raised Malpractice Theories Cannot Defeat Summary Judgment; PHL § 2801-d Claims Require Proof of a Specific Rights Violation

Date: Apr 2, 2026

Ignatiadis v. Shorefront: Conclusory Expert Affidavits and Newly Raised Malpractice Theories Cannot Defeat Summary Judgment; PHL § 2801-d Claims Require Proof of a Specific Rights Violation 1....

Interstate Joint Custody Becomes Unworkable at School Age: Change in Circumstances, Sole Custody, and Recalibrated Long-Distance Parenting Time

Date: Apr 2, 2026

Interstate Joint Custody Becomes Unworkable at School Age: Change in Circumstances, Sole Custody, and Recalibrated Long-Distance Parenting Time 1. Introduction Matter of Zielazny v Martorano (2026 NY...

Lack of Informed Consent Must Be Pleaded (Not Added by Bill of Particulars); Unopposed Malpractice Theories Are Dismissed on Summary Judgment

Date: Mar 29, 2026

Lack of Informed Consent Must Be Pleaded (Not Added by Bill of Particulars); Unopposed Malpractice Theories Are Dismissed on Summary Judgment Introduction In Heather J. v Rochester Regional Health...

Lease Reformation for Mutual Mistake Extinguishes Option-Based Claims, While Co-Venturer Fiduciary Duties May Survive a Business Fallout

Date: Mar 29, 2026

Lease Reformation for Mutual Mistake Extinguishes Option-Based Claims, While Co-Venturer Fiduciary Duties May Survive a Business Fallout Case: Laun v Stewart, 2026 NY Slip Op 01883 (App Div, 4th Dept...

Arruda v. New York Central Mutual: Water-Backup and Earth-Movement Exclusions Bar Coverage Beyond Limited Endorsement; CPLR 3212(f) Requires a Concrete Showing

Date: Mar 28, 2026

Arruda v. New York Central Mutual: Water-Backup and Earth-Movement Exclusions Bar Coverage Beyond Limited Endorsement; CPLR 3212(f) Requires a Concrete Showing 1. Introduction In Arruda v New York...

Fogel v. Kaleida Health: Pleading “Improper Practices” Under Public Health Law § 2801-b Without Naming the Statute; PHHPC Findings Not Preclusive

Date: Mar 28, 2026

Fogel v. Kaleida Health: Pleading “Improper Practices” Under Public Health Law § 2801-b Without Naming the Statute; PHHPC Findings Not Preclusive 1. Introduction Case: Fogel v Health, 2026 NY Slip Op...

Diligent Efforts for Incarcerated Parents: Agency Repeated Attempts and Incarceration-Related Visitation Barriers May Satisfy Social Services Law § 384-b

Date: Mar 28, 2026

Diligent Efforts for Incarcerated Parents: Agency Repeated Attempts and Incarceration-Related Visitation Barriers May Satisfy Social Services Law § 384-b Decision: Matter of Jonah M. (Davion D.),...

Prosecutorial Charge Selection Under Penal Law former § 130.96 Does Not Implicate Apprendi; General CSAAS Testimony Remains Admissible

Date: Mar 28, 2026

Prosecutorial Charge Selection Under Penal Law former § 130.96 Does Not Implicate Apprendi; General CSAAS Testimony Remains Admissible Introduction People v Litolff (Appellate Division, Fourth...

People v. Mitchell: Denial of Late CPL 250.10 Psychiatric Notice Absent Good Cause; Trespass Lesser-Included Charge Properly Refused Where No Reasonable View of Innocent Entry

Date: Mar 28, 2026

People v. Mitchell: Denial of Late CPL 250.10 Psychiatric Notice Absent Good Cause; Trespass Lesser-Included Charge Properly Refused Where No Reasonable View of Innocent Entry 1. Introduction In...

People v. Williams (4th Dept 2026): Admitting Prior CPL Article 440 Testimony as an Exculpatory Declaration Against Penal Interest When the Witness Invokes the Fifth

Date: Mar 28, 2026

Admitting Prior CPL Article 440 Testimony as an Exculpatory Declaration Against Penal Interest When the Witness Invokes the Fifth 1. Introduction In People v Williams, 2026 NY Slip Op 01881 (App Div...

Briggs v. Fresenius: CPLR 306-b Bars Sua Sponte Dismissal for Defective/Untimely Service; Vacatur Required in Substantial Justice

Date: Mar 28, 2026

Briggs v. Fresenius: CPLR 306-b Bars Sua Sponte Dismissal for Defective/Untimely Service; Vacatur Required in Substantial Justice 1. Introduction Briggs v Fresenius (App Div 3d Dept, Mar. 26, 2026)...