Justia New York Court of Appeals Opinion Summaries

In IRB-Brasil Resseguros, S.A. v. Inepar Invs., S.A., the Court of Appeals held that, where parties include a New York choice-of-law clause in a contract, such a provision demonstrates the parties’ intent that courts not conduct a conflict-of-laws analysis. In the instant case, Plaintiff was a New York not-for-profit corporation that administered a retirement plan and a death benefit plan. Decedent was enrolled in both plans. Decedent named Appellants as beneficiaries. Both plans stated that they shall be governed by and construed in accordance with New York law. After Decedent died, a Colorado court admitted his will to probate. Plaintiff was unsure to whom the plan benefits should be paid after Decedent’s death and commenced a federal interpleader action against Decedent’s Estate, the personal representative (PR) of the Estate, and Appellants. A federal district court directed Plaintiff to pay the disputed funds to the PR, concluding that Colorado’s revocation law terminated any claims to the plans by Appellants. On appeal, the Second Circuit Court of Appeals certified questions to the Court of Appeals. The Court of Appeals answered by extending the holding in IRB to contracts that do not fall under Gen. Oblig. Law 5-1401 and clarifying that this rule obviates the application and both common-law and conflict-of-laws principles and statutory choice-of-law directives, unless the parties expressly indicate otherwise. View "Ministers & Missionaries Benefit Bd. v. Snow" on Justia Law

Petitioners, including individual residents of the Village of Painted Post, commenced this N.Y. C.P.L.R. 78 proceeding against the Village and others (collectively, Respondents), asserting that the Village failed to comply with the strict procedural mandates of the State Environmental Quality Review Act by entering into a bulk water sale agreement with a subsidiary of Shell Oil Co. providing for the sale of 314 million gallons of water from the village water system and by approving a lease agreement with a railroad for the construction of a water transloading facility. Respondents moved to dismiss the petition, asserting that Petitioners lacked standing and failed to state a cause of action. Supreme Court denied Respondents’ motion to dismiss for lack of standing after finding that one of the individual petitions had standing. The Appellate Division reversed and dismissed the petition on the ground that the individual petitioner lacked standing. The Court of Appeals reversed, holding that the Appellate Division, in concluding that the individual petitioner at issue lacked standing, applied an overly restrictive analysis of the requirement to show harm “different from that of the public at large.” View "Sierra Club v. Village of Painted Post" on Justia Law

Two certificateholders in ACE Securities Corp., Home Equity Loan Trust sued DB Structured Products (DBSP) for failure to repurchase loans that purportedly did not conform to the representations and warranties of DBSP, which sponsored the transaction. The Trust later sought to substitute itself as plaintiff in place of the certificateholders. DBSP moved to dismiss the complaint as untimely, arguing that the Trust’s claims accrued as of March 28, 2006, more than six years before the Trust filed its complaint. DBSP further contended that the certificateholders did not validly commence this action and lacked standing to sue. Supreme Court denied DBSP’s motion to dismiss and held the Trust’s action to be timely.The Appellate Division reversed. The Court of Appeals affirmed, holding (1) the Trust’s cause of action against DBSP for breach of representations and warranties accrued at the point of contract execution on March 28, 2006; and (2) even assuming that the certificateholders possessed standing to sue, the two certificateholders did not validly commence this action because they failed to comply with the contractual condition precedent to suit. View "ACE Sec. Corp. v DB Structured Prods., Inc." on Justia Law

In June 2008, Plaintiff brought an action in a federal district court alleging violations of her federal and state constitutional rights and asserting common law negligence claims. The district dismissed several of Plaintiff’s claims. On September 30, 2011, the court granted Defendants’ motion for summary judgment and dismissed Plaintiff’s remaining federal claims. Plaintiff appealed. Because Plaintiff failed to file her brief and appendix by an extended deadline, the Second Circuit dismissed Plaintiff’s appeal by mandate issued on August 28, 2012, effective July 10, 2012. On June 25, 2012, Plaintiff commenced the instant action in Supreme Court. Defendants moved to dismiss the state action as untimely, contending that the six-month tolling period provided by N.Y. C.P.L.R. 205(a) had already expired. Supreme Court granted the motion to dismiss, concluding that Plaintiff’s federal action terminated on September 30, 2011, thus rejecting Plaintiff’s contention that her federal action terminated with the Second Circuit’s dismissal of her appeal. The Court of Appeals reversed, holding that, where an appeal is taken as of right, the prior action terminates for purposes of section 205(a) when the nondiscretionary appeal is “exhausted,” either by a determination on the merits or by dismissal of the appeal. View "Malay v. City of Syracuse" on Justia Law

Plaintiff, a resident of Alberta, Canada, commenced an action against Defendants in a New York federal court asserting various RICO claims stemming from a dispute over control of an oil field in Siberia. The Second Circuit Court of Appeals eventually dismissed the complaint for failure to state a claim, concluding that a United States federal court could not provide relief. Within six months of the federal action’s termination, Plaintiff refiled in Supreme Court claims arising from the same transaction. Defendants moved to dismiss the complaint, arguing that it was untimely because Plaintiff’s injuries accrued in Alberta, and Plaintiff’s claim was untimely under Alberta law. Supreme Court dismissed Plaintiff’s complaint as time-barred, concluding that New York’s borrowing statute required her to apply Alberta's shorter limitations period to determine if Plaintiff’s state court action was timely. The Appellate Division affirmed. The Court of Appeals reversed, holding that New York’s savings statute permitted the “new” state court action because its “prior” federal court action was timely under the borrowing statute. View "Norex Petroleum Ltd. v. Blavatnik" on Justia Law

This case arose out of a transaction between a bank located in United Arab Emirates and a partnership which had its headquarters in Saudi Arabia. The bank sued the partnership to collect an alleged debt and chose to do so in New York Supreme Court. The partnership filed a third-party complaint against a citizen of Saudi Arabia (“citizen”) and a bank headquartered in the Kingdom of Bahrain. The citizen moved to dismiss the third-party complaint on the ground of forum non conveniens. After the issue was briefed and argued at Supreme Court, the court dismissed both the complaint and the third-party complaint on forum non conveniens grounds. The Appellate Division reversed, concluding that VSL Corp. v. Dunes Hotels & Casinos, Inc. prohibited the dismissal of the main action on forum non conveniens grounds in the absence of a motion seeking that relief and that the dismissal of the third-party complaint was an abuse of discretion. The Court of Appeals reversed, holding (1) VSL did not bar Supreme Court from dismissing the complaint under the circumstances of this case; and (2) Supreme Court was correct as a matter of law in dismissing both the complaint and the third-party complaint. View "Mashreqbank PSC v. Ahmed Hamad A1 Gosaibi & Bros. Co." on Justia Law