New York Case Commentaries

Prospective-Only Licensing under RPAPL § 881 and Judicial Power to Revive Expired Access Terms: Commentary on Franklin Carroll, LLC v. Carroll Development Plaza, LLC (2025)

Date: May 8, 2025

Prospective-Only Licensing under RPAPL § 881 and Judicial Power to Revive Expired Access Terms Commentary on Franklin Carroll, LLC v. Carroll Development Plaza, LLC (2025) Introduction The Appellate...

Conte v. Tri-State Tech.: Affidavits Are Not “Documentary Evidence” Under CPLR 3211(a)(1) and Pleading Standards for Wage-and-Hour Claims Clarified

Date: May 8, 2025

Conte v. Tri-State Tech.: Affidavits Are Not “Documentary Evidence” Under CPLR 3211(a)(1) and Pleading Standards for Wage-and-Hour Claims Clarified 1. Introduction Conte v. Tri-State Technologies,...

Extending the “Gravity-Related Hazard” Doctrine to Work on Permanent Staircases: Commentary on Cagua v. Bushwick Holdings, LLC (2025 NY Slip Op 02753)

Date: May 8, 2025

Extending the “Gravity-Related Hazard” Doctrine to Work on Permanent Staircases: Commentary on Cagua v. Bushwick Holdings, LLC (App. Div. 2d Dep’t 2025) Introduction Cagua v. Bushwick Holdings, LLC...

Langton v. Sussman & Watkins: The Clarified Threshold for Pleading Attorney Deceit under Judiciary Law § 487 and the Appellate Division’s Re-affirmation of its Anti-Vexatious-Litigation Power

Date: May 8, 2025

Langton v. Sussman & Watkins: The Clarified Threshold for Pleading Attorney Deceit under Judiciary Law § 487 and the Appellate Division’s Re-affirmation of its Anti-Vexatious-Litigation Power...

“From Notice to Action” – The Donaldson Standard on Engineering Delays and Suicide-Prevention Duties for Bridge Owners

Date: May 7, 2025

“From Notice to Action” – The Donaldson Standard on Engineering Delay, Suicide-Prevention Measures and the Bridge Owner’s Duty of Reasonable Care Introduction Donaldson v. Port Authority of New York...

Reaffirming the Mandatory Nature of Abatement Ab Initio in New York: People v. Cruciani & People v. Nowell (2025)

Date: May 7, 2025

Reaffirming the Mandatory Nature of the Abatement Ab Initio Doctrine in New York: Appellate Division Maintains that Only the Court of Appeals or the Legislature May Alter the Rule 1. Introduction The...

“Stay Within the Mandate”: Effective Assistance of Counsel on Remittal after People v. Nathan (2025)

Date: May 3, 2025

“Stay Within the Mandate”: Effective Assistance of Counsel on Remittal after People v. Nathan (2025) Introduction The Fourth Department’s 2025 decision in People v. Nathan, 238 A.D.3d 1516, tackles a...

People v. Vanderbilt (2025): The Appellate Division Re-Affirms a Flexible “Searching Inquiry” and Rejects a Per-Se Pedigree Requirement for Waiver of Counsel

Date: May 3, 2025

People v. Vanderbilt (2025): The Appellate Division Re-Affirms a Flexible “Searching Inquiry” and Rejects a Per-Se Pedigree Requirement for Waiver of Counsel Introduction People v. Vanderbilt, 238...

People v. Dozier (2025): Competency ≠ Criminal Responsibility – The Appellate Division Distinguishes CPL Article 730 Exams from Psychiatric Defenses

Date: May 3, 2025

People v. Dozier (2025): Competency ≠ Criminal Responsibility – The Appellate Division Distinguishes CPL Article 730 Exams from Psychiatric Defenses Introduction In People v. Dozier, 238 A.D.3d 1523...

The Immutable-Conviction-Date Rule: Matter of Trubitsky (2025)

Date: May 2, 2025

The Immutable-Conviction-Date Rule for Automatic Disbarment Commentary on Matter of Trubitsky, 2025 NY Slip Op 02649 (1st Dept.) Introduction Matter of Trubitsky presents a straightforward but...

“Nunc Pro Tunc Reciprocity” – Matter of Stafford Establishes Equitable Timing in Cross-Jurisdictional Attorney Discipline

Date: May 2, 2025

“Nunc Pro Tunc Reciprocity” – Matter of Stafford Establishes Equitable Timing in Cross-Jurisdictional Attorney Discipline Introduction Matter of Stafford (2025 NY Slip Op 02648) is a First Department...

Misstep Falls Are Not “Accidents,” and Two-Year Continuous Light-Duty Assignment Sets the Incapacity Baseline for Performance-of-Duty Disability

Date: May 2, 2025

Misstep Falls Are Not “Accidents,” and Two-Year Continuous Light-Duty Assignment Sets the Incapacity Baseline for Performance-of-Duty Disability 1. Introduction Matter of Cuppek v DiNapoli (2025 NY...

Opiate Overdose in a Child’s Presence Supports Neglect and Derivative Neglect; Non-Testimony Permits the Strongest Negative Inference; Clear-and-Convincing Proof Establishes Willful Order-of-Protection Violations

Date: May 2, 2025

Opiate Overdose in a Child’s Presence Supports Neglect and Derivative Neglect; Non-Testimony Permits the Strongest Negative Inference; Clear-and-Convincing Proof Establishes Willful...

Carrier Must Timely Seek Extensions for Cross-Examination Depositions; Preclusion Improper Where Subpoenas Were Issued Knowing Nonappearance and No Extension Was Requested

Date: May 2, 2025

Carrier Must Timely Seek Extensions for Cross-Examination Depositions; Preclusion Improper Where Subpoenas Were Issued Knowing Nonappearance and No Extension Was Requested 1. Introduction Matter of...

“Separate-and-Distinct-Acts” Re-Defined: Consecutive Sentencing Limited to Facts Admitted at Plea in People v. Sabb (2025)

Date: May 2, 2025

“Separate-and-Distinct-Acts” Re-Defined: Consecutive Sentencing Limited to Facts Admitted at Plea A Commentary on People v. Sabb, 238 A.D.3d 1212 (3d Dep’t 2025) 1. Introduction People v. Sabb arises...

People v. Hooper: Broken Permanent Tooth as “Serious Physical Injury” and the Required Lesser-Included Charge When Intent/Severity Is in Dispute

Date: May 2, 2025

People v. Hooper: Broken Permanent Tooth as “Serious Physical Injury” and the Required Lesser-Included Charge When Intent/Severity Is in Dispute 1. Introduction In People v Hooper (2025 NY Slip Op...

Untreated, Dangerous Mental Health Conditions as “Extraordinary Circumstances” Justifying Nonparent Custody and Suspension of Parental Visitation

Date: May 2, 2025

Untreated, Dangerous Mental Health Conditions as “Extraordinary Circumstances” Justifying Nonparent Custody and Suspension of Parental Visitation 1. Introduction In Matter of Tamara GG. v Danielle...

Hernandez v. Port Authority (2025): Expanding §240(1) Coverage to Heavy Ground-Level Loads and Re-mapping Indemnity Obligations on Complex Construction Sites

Date: May 2, 2025

Hernandez v. Port Authority (2025): Expanding Labor Law §240(1) Coverage to Heavy Ground-Level Loads and Re-mapping Indemnity Obligations on Complex Construction Sites Introduction In Hernandez v....

Restoration-Cost-Only Damages Charge Where No Diminution Proof Is Offered in Real-Property Injury Claims

Date: May 2, 2025

Restoration-Cost-Only Damages Charge Where No Diminution Proof Is Offered in Real-Property Injury Claims Introduction In Fusco v Town of Colonie (2025 NY Slip Op 02629 [238 AD3d 1226] [3d Dept May 1,...

Keller v. Keller: Documentary Contradictions Bar Fraudulent-Inducement Challenges to Post-Divorce Stipulations

Date: May 1, 2025

Keller v. Keller: Documentary Contradictions Bar Fraudulent-Inducement Challenges to Post-Divorce Stipulations Introduction Keller v. Keller (2025 NY Slip Op 02581) is a significant decision from the...