Justia New York Court of Appeals Opinion Summaries

A property owner sought to develop a parcel of land in a town, which required rezoning and environmental review. In 2017, while preparing its zoning petition, the owner and the town entered into a memorandum of understanding (MOU) that purported to bind the town and its successors to continue reviewing the zoning petition until a final determination was reached, based on empirical data. The owner submitted its petition and participated in the environmental review process, investing significant resources. After local elections in 2019, a new town supervisor and board, who opposed the project, voted to terminate review of the zoning petition and the related environmental process.The property owner filed suit against the town, its board, and the supervisor, alleging breach of contract and breach of the implied covenant of good faith and fair dealing, based on the town’s termination of the review process. The defendants moved to dismiss, arguing that the MOU was unenforceable under the term limits doctrine and contract zoning doctrine. The Supreme Court, Dutchess County, dismissed the complaint, holding the MOU invalid. The Appellate Division, Second Department, affirmed that decision.The New York Court of Appeals reviewed the case after granting leave to appeal. The Court held that the MOU was invalid and unenforceable under the term limits doctrine because it impermissibly bound successor town boards in the exercise of their legislative discretion over zoning matters. The Court found that such an agreement was not specifically authorized by statute or charter, and did not fall within an exception for proprietary acts. As a result, the property owner’s contractual claims failed as a matter of law. The Court affirmed the Appellate Division’s order. View "Hudson View Park Co. v Town of Fishkill" on Justia Law

The case involves an individual who left his Florida residence in August 2018 to care for his terminally ill brother, a tenant in a New York City Mitchell-Lama apartment. After the brother’s death in March 2020, the petitioner sought succession rights to the apartment, which required him to prove that the apartment was his primary residence for at least one year prior to his brother’s death. The petitioner submitted various documents, including income certifications, power of attorney forms, and certain public assistance records. However, some materials listed his Florida address, and much of his supporting documentation either fell outside the relevant one-year period or was not addressed to the apartment in question.The housing company denied his application, concluding that he failed to establish primary residency during the required time. The New York City Department of Housing Preservation and Development (HPD) upheld this decision after an administrative appeal, finding the evidence insufficient. The petitioner then challenged the agency’s determination through a CPLR article 78 proceeding. The Supreme Court annulled the agency’s decision and granted succession rights, ruling the denial irrational. On appeal, the Appellate Division reversed, holding that the agency’s denial had a rational basis, especially given the petitioner’s failure to supply certain key documents such as New York State tax returns or proof of exemption.The New York Court of Appeals affirmed the Appellate Division’s decision. The Court held that, under the applicable regulations, the agency’s determination that the petitioner failed to prove the apartment was his primary residence for the required period was supported by a rational basis. The Court emphasized that the agency’s decision was neither arbitrary nor capricious, and the evidence provided by the petitioner did not meet the burden required to establish primary residency for succession rights. The order dismissing the petition was affirmed. View "Matter of Mantilla v New York City Dept. of Hous. Preserv. & Dev." on Justia Law

A carpenter employed by a subcontractor was injured after falling from a ladder owned by another subcontractor, DAL Electrical Corporation, while working on a renovation project at an office building. The injured worker was using his own employer’s equipment in the morning but, after lunch, returned to the worksite without his equipment and used an unattended DAL ladder, which was defective and marked with blue tape. He was injured when the ladder wobbled and he fell, impaling himself on a tool in his belt. The worker brought claims under New York Labor Law and for common-law negligence against the project’s general contractor, premises owner, and DAL, asserting the defective ladder caused his injuries. The general contractor and owner sought indemnification from DAL under their subcontract.The Supreme Court of Bronx County granted the worker’s motion for partial summary judgment on one Labor Law claim and denied DAL’s motion to dismiss other claims and cross-claims by the general contractor and owner. The court also granted the general contractor and owner summary judgment on their contractual indemnification claim against DAL. The Appellate Division, First Department, modified this order by denying summary judgment on contractual indemnification and granting summary judgment for DAL on all claims and cross-claims against it. The general contractor and owner appealed to the New York Court of Appeals.The New York Court of Appeals affirmed the Appellate Division’s decision. The Court held that none of the indemnification provisions in the subcontract required DAL to indemnify the general contractor or owner for the worker’s injuries because the injuries did not arise from DAL’s performance of its contractually defined work. The Court also found that DAL did not owe a duty of care in tort to the injured worker, as the facts did not fit within any recognized exception to the general rule against extending contractual duties to non-contracting third parties. The certified question was answered in the affirmative. View "Dibrino v Rockefeller Ctr. N., Inc." on Justia Law

The plaintiff was hired as a “Full Time Jewish Educator” at a religious institution and was responsible for teaching in religious classrooms, planning and attending religious events, and supporting the synagogue’s mission to develop a strong Jewish identity. Soon after starting her job, the plaintiff was confronted by a rabbi about her co-authorship of a blog post that was critical of Israel and Zionism. Although she assured the rabbi she would not share her personal views at work and was told her teaching abilities were not in question, she was terminated less than a week later.The plaintiff filed suit in New York Supreme Court, alleging that her dismissal violated Labor Law § 201-d(2)(c), which prohibits employers from taking adverse action against employees for engaging in legal recreational activities outside of work. The defendants moved to dismiss, arguing the claim failed because the activity was not protected, there was a material conflict with the employer’s interests, and the ministerial exception barred the claim. The Supreme Court granted the motion to dismiss, holding that the complaint failed to state a cause of action because the termination was for the content of the blog post, not the act of blogging itself, and did not address the other grounds for dismissal. The Appellate Division affirmed on the same basis and declined to reach the alternative arguments.The New York Court of Appeals affirmed the Appellate Division’s order, but on a different ground. The Court of Appeals held that, regardless of whether the plaintiff’s activity was protected under Labor Law § 201-d, the ministerial exception—which bars application of employment discrimination laws to the employment relationship between a religious institution and its ministers—applied. The plaintiff’s offer letter conclusively established that her core duties were religious in nature, and thus her claim was barred as a matter of law. View "Sander v. Westchester Reform Temple" on Justia Law

A company that owns and operates the only landfill in a particular town challenged a local law that required the landfill’s closure by a specified date. The law was enacted after community complaints regarding odors. When the law was first passed, the town’s attorney acknowledged that a State Environmental Quality Review Act (SEQRA) review was required, but the Board adopted the law and related SEQRA documents without substantive discussion. After a subsequent law rescinded and then court action reinstated the original law, the landfill owner again brought a proceeding, claiming, among other things, that the Board failed to comply with SEQRA by not taking a “hard look” at environmental impacts.The Supreme Court initially dismissed the action on statute of limitations grounds, but the Appellate Division, Fourth Department, reversed that decision, holding the claim was timely. After the parties resolved all non-SEQRA claims, Supreme Court granted summary judgment to the landfill owner, finding it had standing and that the Board did not properly comply with SEQRA. The Appellate Division reversed, concluding the owner lacked standing because it had not shown it suffered or would suffer an environmental injury. The dissent argued that under Matter of Har Enterprises v Town of Brookhaven and Gernatt Asphalt Products v Town of Sardinia, property owners directly affected by a government action do not need to allege environmental harm to have standing under SEQRA.The New York Court of Appeals held that the landfill owner has standing to challenge the Board’s SEQRA compliance simply by virtue of owning property directly affected by the local law, following the holdings in Har Enterprises and Gernatt Asphalt Products. The Court further declined to review the statute of limitations argument at this stage, as that issue had already been resolved and was not properly before it. The Court of Appeals reversed the Appellate Division’s order and remitted the case for further proceedings. View "Seneca Meadows, Inc. v. Town of Seneca Falls" on Justia Law

During the COVID-19 pandemic, full-time civil service employees working as instructors and teachers at facilities operated by the New York State Department of Corrections and Community Supervision sought unemployment benefits when their optional summer work was suspended in 2020. These employees, paid an annual salary under a collective bargaining agreement, applied for regular state unemployment benefits as well as federal pandemic-related benefits authorized by the CARES Act. Initially, their applications for benefits were granted. However, the New York State Department of Labor subsequently determined that, because the employees continued to receive their annual salary and did not meet the statutory requirements for "total unemployment" under state law, they were ineligible for both state and federal benefits, and were charged with overpayments.After hearings, Administrative Law Judges upheld the Department of Labor’s revised determinations, concluding that the claimants were not entitled to benefits due to failure to meet the "total unemployment" requirement. The Unemployment Insurance Appeal Board affirmed these decisions. On further appeal, the Appellate Division also affirmed, finding that substantial evidence supported the Board’s determination that the claimants were not "totally unemployed" during the summer in question. The court reasoned that the annual salary compensated the claimants for the entire year, including the summer, making them ineligible for unemployment benefits under state law and, consequently, ineligible for federal pandemic benefits.The New York Court of Appeals reviewed the case and held that the Department of Labor properly applied New York’s "total unemployment" requirement when evaluating eligibility for both CARES Act and related federal benefits. The court concluded that this requirement does not conflict with the CARES Act, which does not define "unemployed" or "partially unemployed" and incorporates state law for determining benefit eligibility. The court affirmed the orders of the Appellate Division. View "Klosterman v. Department of Corrections and Community Supervision" on Justia Law

In this case, a motorist was stopped by state troopers for traffic infractions. The troopers observed signs of intoxication, and after the motorist failed a field sobriety test, he refused to take a chemical breath test, even after being warned multiple times about the consequences. Following his refusal, the troopers completed and signed sworn reports documenting the events, and his driver's license was automatically suspended pending a Department of Motor Vehicles (DMV) hearing to determine if it should be revoked for refusing the chemical test.At the DMV hearing, which was postponed once when the troopers failed to appear, the motorist again properly subpoenaed both troopers for the rescheduled hearing. When the troopers did not attend the second hearing, the Administrative Law Judge (ALJ) acknowledged the validity of the subpoenas but proceeded with the hearing without further adjournment. The ALJ admitted the troopers’ sworn written reports and supporting depositions as evidence and, over the motorist’s objections, found that the elements required for license revocation were met. On administrative appeal, the DMV Appeals Board affirmed, and upon transfer, the Appellate Division confirmed the DMV’s decision, reasoning that the motorist had made a tactical choice not to seek judicial enforcement of the subpoenas or request another adjournment.The New York Court of Appeals reviewed the matter. The court held that when a motorist properly subpoenas officers in a DMV license revocation hearing and the officers fail to appear, due process does not require dismissal of the charge or exclusion of their written reports unless the motorist first seeks judicial enforcement of the subpoenas pursuant to CPLR 2308(b). As the motorist in this case did not pursue enforcement or request an adjournment to do so, his due process rights were not violated. The court affirmed the Appellate Division’s order. View "Monaghan v. Schroeder" on Justia Law

In this case, the defendant was charged following two shootings in Buffalo, New York, that occurred about an hour apart on August 4, 2016, resulting in one death and three injuries. Key evidence included witness accounts and surveillance footage showing a shooter in distinctive clothing matching what the defendant wore earlier that day. Forensic testimony linked the fatal weapon to an individual depicted in the videos. After trial, the jury convicted the defendant of murder in the second degree, assault in the first degree, and criminal possession of a weapon in the second degree, while acquitting him of two counts of attempted murder.During jury deliberations, a juror raised concerns that another juror had made a racially biased remark. The trial judge questioned both the reporting juror and the accused juror individually, with input from counsel, but did not question other jurors. Defense counsel moved for a mistrial based on alleged racial bias affecting up to six jurors but declined to request further inquiry or substitution of jurors, relying solely on the mistrial request. The trial judge denied the motion, finding no convincing evidence of grossly unqualified jurors or racial animus affecting deliberations, and subsequently denied a post-verdict motion to set aside the verdict.The Appellate Division, Fourth Department, reviewed the trial court’s response and concluded that the judge had conducted an appropriate inquiry into the allegations and did not abuse discretion by denying the mistrial request. Upon further appeal, the New York State Court of Appeals held that the trial court’s inquiry was sufficient, that the record did not convincingly demonstrate a lack of impartiality among the jurors, and that the denial of the motion for a mistrial was not an abuse of discretion. The Court of Appeals therefore affirmed the order of the Appellate Division. View "People v Wiggins" on Justia Law

The case concerns a borrower who executed a promissory note and mortgage in 2007, defaulted on the loan in 2009, and faced a foreclosure action that same year by the lender's predecessor. The 2009 foreclosure action included an explicit acceleration of the loan, but the lender’s standing was disputed due to the timing of the assignment of the note and mortgage. The foreclosure case lingered for over a decade, during which the mortgage and note changed hands and were eventually assigned to the current lender. In 2022, the foreclosure action was voluntarily discontinued without prejudice. Shortly thereafter, the borrower brought a quiet title action, contending that the six-year statute of limitations had expired, making further foreclosure unenforceable. The lender then initiated a new foreclosure action, which was also pending.In the Supreme Court of New York County, the lender argued that the loan was never validly accelerated due to lack of standing in the original case. The borrower sought summary judgment, asserting that under the recently enacted Foreclosure Abuse Prevention Act (FAPA), the limitations period had expired. While the motions were pending, FAPA took effect. The Supreme Court found that FAPA applied retroactively, estopped the lender from challenging the validity of the 2009 acceleration, and granted judgment for the borrower, cancelling the mortgage. The Appellate Division unanimously affirmed this decision.The New York Court of Appeals reviewed the case. It held that FAPA’s relevant provisions (sections 4, 7, and 8) apply retroactively to pending actions and do not violate the federal Due Process or Contract Clauses. The Court found that FAPA validly estops the lender from disputing the prior acceleration and that the limitations period had expired, supporting quiet title relief for the borrower. The order of the Appellate Division was affirmed. View "Van Dyke v U.S. Bank, Natl. Assn." on Justia Law

In this case, the dispute centered on a Brooklyn property subject to both senior and junior mortgages. After the original borrower defaulted on the senior mortgage, a loan servicer (Central Mortgage Company) commenced a foreclosure action in 2007 but later discontinued it without prejudice in 2017. Subsequently, Article 13 LLC acquired the junior mortgage and, in 2020, filed a quiet title action in federal court seeking to have the senior mortgage canceled as time-barred under New York’s statute of limitations.The United States District Court for the Eastern District of New York initially found that there were material factual disputes regarding whether the servicer actually held the note at the time it commenced the 2007 foreclosure, denying both parties’ motions for summary judgment. Shortly thereafter, the New York Legislature enacted the Foreclosure Abuse Prevention Act (FAPA), which clarified the statute of limitations for mortgage foreclosures and addressed abusive litigation practices. Article 13 LLC moved for reconsideration, arguing the new law applied retroactively. The district court agreed, concluding that FAPA retroactively applied and precluded the senior mortgage holder from contesting the validity of the prior foreclosure acceleration, and further held that this retroactive effect did not violate due process rights.On appeal, the United States Court of Appeals for the Second Circuit certified two questions to the New York Court of Appeals regarding the retroactive application of FAPA and its consistency with the New York Constitution’s due process protections. The New York Court of Appeals held that FAPA applies to all foreclosure actions in which a final judgment of foreclosure and sale had not been enforced before its effective date, including those pending at the time of enactment. The court further held that FAPA’s retroactive application does not violate substantive or procedural due process under the New York Constitution. View "Article 13 LLC v Ponce De Leon Fed. Bank" on Justia Law