You are here: / SECURITY OFFICERS NOT EMPLOYEES OF PLACEMENT SERVICE.

Search Results

/

SECURITY OFFICERS NOT EMPLOYEES OF PLACEMENT SERVICE.

The Third Department, reversing the Unemployment Insurance Appeal Board, determined claimant security officer was not an employee of TMR, which was essentially a placement service which posted security jobs on a secure website:

TMR posted security-related jobs on a secure website for its clients, who dictated the hours to be worked, as well as the scope of services that were needed. The security officers, after browsing through these postings, would request to work on any particular job, which TMR ultimately awarded on a “first come, first serve” basis. The security officers were free to select a job that they wanted and were not prohibited from seeking jobs from TMR’s competitors. TMR did not provide the security officers with training or equipment nor did TMR pay the security officers a set hourly rate. Furthermore, once TMR placed the security officer with a client, TMR did not enter into a contract with the security officer. While a security officer could be in the middle of a continuing job for a client, he or she was nonetheless free to leave at any point and work elsewhere. In addition, if an issue arose with the security officer’s performance, the client dealt with the security officer directly, and TMR would be notified if it needed to provide a substitute security officer. Matter of TMR Sec. Consultants, Inc. (Commissioner of Labor), 2016 NY Slip Op 08922, 3rd Dept 12-29-16

UNEMPLOYMENT INSURANCE (SECURITY OFFICERS NOT EMPLOYEES OF PLACEMENT SERVICE)/SECURITY OFFICERS (UNEMPLOYMENT INSURANCE, SECURITY OFFICERS NOT EMPLOYEES OF PLACEMENT SERVICE)

/

COURT SHOULD NOT HAVE GIVEN HUSBAND CREDIT FOR HIGHER CHILD SUPPORT PAYMENTS MADE BEFORE THE LOWER FINAL CHILD SUPPORT AWARD UPON DIVORCE.

The Third Department, in this divorce action, determined that Supreme Court’s attempt to give the husband credit for the difference between the higher child support payments imposed prior to the divorce and the lower payments ordered in the final child support award was error:

… [T]he temporary support payments already made by the husband pursuant to the pendente lite order exceeded the retroactive support obligation set forth by Supreme Court. Absent any statutory authority for recoupment of overpayments of child support and given the “‘strong public policy against restitution or recoupment of [such] overpayments'” … , we conclude that Supreme Court erred in crediting the husband for the temporary child support payments that he made in excess of what he was required to pay under the final child support award … . Sprole v Sprole, 2016 NY Slip Op 08911, 3rd Dept 12-29-16

FAMILY LAW (CHILD SUPPORT, COURT SHOULD NOT HAVE GIVEN HUSBAND CREDIT FOR HIGHER CHILD SUPPORT PAYMENTS MADE BEFORE THE LOWER FINAL CHILD SUPPORT AWARD UPON DIVORCE)/CHILD SUPPORT (CHILD SUPPORT, COURT SHOULD NOT HAVE GIVEN HUSBAND CREDIT FOR HIGHER CHILD SUPPORT PAYMENTS MADE BEFORE THE LOWER FINAL CHILD SUPPORT AWARD UPON DIVORCE)

/

BLOGGER FOR THE NATION MAGAZINE NOT AN EMPLOYEE.

The Third Department, in an extensive decision, reversed the Unemployment Insurance Appeal Board and found that claimant, a blog writer for the The Nation magazine, was not an employee and therefore was not entitled to unemployment insurance benefits:

At the outset, we are satisfied that claimant — an experienced, well-known and established writer, author and media critic — qualifies as a professional for purposes of our analysis. Hence, our focus will be whether the company exercised “control over important aspects of the services performed” by claimant … . …

While it is true that claimant was required to identify himself as a writer for The Nation, was paid an annual salary in monthly installments and was reimbursed for certain business-related expenses, it is equally true that claimant received a 1099 form each year, filed his taxes as self-employed, was not required to obtain permission prior to taking a vacation and neither received fringe benefitnor was covered by the union contract pertaining to The Nation’s staff writers … . …

Turning to the actual degree of supervision or control exercised over claimant’s work, the record reveals that claimant was not formally interviewed for his position … , worked from home utilizing his personal laptop, set his own hours and did not suffer any adverse consequences if he did not post a story … . Additionally, claimant did not have a supervisor …  and was not permitted to work from The Nation’s offices. Significantly, the record makes clear that claimant generally was not assigned to write on a particular topic and could post a story to his blog prior to it being edited by The Nation’s staff … . * * *

Although claimant was given “a broad direction to write about the media . . . and politics,” “the contents of the post and the topic were really . . . entirely his choice.” Unlike staff writers, claimant could not be compelled to write on a particular topic and, while The Nation preferred that claimant post his articles early in the workday and that such articles be submitted for editorial review prior to posting on the website, the senior editor made clear that claimant had no established work hours, could post whenever and from wherever he wished and that there were “no repercussions” and “no consequences” if claimant posted an article later in the day without editorial review or, alternatively, did not post at all on a given day. Matter of Mitchell (Nation Co. Ltd. Partners — Commissioner of Labor), 2016 NY Slip Op 08923, 3rd Dept 12-29-16

 

UNEMPLOYMENT INSURANCE (BLOGGER FOR THE NATION MAGAZINE NOT AN EMPLOYEE)/WRITERS (UNEMPLOYMENT INSURANCE, BLOGGER FOR THE NATION MAGAZINE NOT AN EMPLOYEE)/BLOGGERS (UNEMPLOYMENT INSURANCE, BLOGGER FOR THE NATION MAGAZINE NOT AN EMPLOYEE)

/ ,

RE TIMELINESS OF CLAIMS ALLEGING DEFECTIVE MORTGAGES UNDERLYING RESIDENTIAL MORTGAGE BACKED SECURITIES, WHERE THE CONTRACT CALLS FOR TIMELY NOTICES OF BREACH, NO NOTICE OF BREACH REQUIRED WHERE DEFENDANT ITSELF DISCOVERS THE DEFECTIVE MORTGAGE.

The First Department, in a full-fledged opinion by Justice Gische, over a dissent, ruled on the timeliness of claims that defendant, GreenPoint Mortgage Funding, had breached representations and warranties regarding the quality of mortgages underlying residential mortgage backed securities (RMBS). The court determined the claims were timely with regard to defective mortgages discovered by the defendant itself, despite the absence of notices of breach. But the claims were not timely with respect to the defective mortgages discovered by the plaintiff but for which no timely notices of breach were provided:

The issues before us are related to the contractual requirement and sufficiency of notices of breach (breach notice). We consider whether a breach notice is required when the underlying contract claim is based upon a defendant’s independent discovery or knowledge of the nonconforming mortgages. We also consider whether an otherwise late breach notice can relate back in time to the commencement of the underlying action in order to avoid dismissal. … [W]e hold that the breach of contract claims based upon defendant’s alleged independent discovery or likely knowledge of nonconforming mortgage loans do not require breach notices to be sent before an action may be brought. We further hold that the doctrine of relation back does not save claims that do require that a breach notice be sent as a precondition to bringing an action. U.S. Bank N.A. v GreenPoint Mtge. Funding, Inc., 2016 NY Slip Op 08968, 1st Dept 12-29-16

SECURITIES (RE TIMELINESS OF CLAIMS ALLEGING DEFECTIVE MORTGAGES UNDERLYING RESIDENTIAL MORTGAGE BACKED SECURITIES, WHERE THE CONTRACT CALLS FOR TIMELY NOTICES OF BREACH, NO NOTICE OF BREACH REQUIRED WHERE DEFENDANT ITSELF DISCOVERS THE DEFECTIVE MORTGAGE)/RESIDENTIAL MORTGAGE BACKED SECURITIES (RE TIMELINESS OF CLAIMS ALLEGING DEFECTIVE MORTGAGES UNDERLYING RESIDENTIAL MORTGAGE BACKED SECURITIES, WHERE THE CONTRACT CALLS FOR TIMELY NOTICES OF BREACH, NO NOTICE OF BREACH REQUIRED WHERE DEFENDANT ITSELF DISCOVERS THE DEFECTIVE MORTGAGE)/CONTRACT LAW (RESIDENTIAL MORTGAGE BACKED SECURITIES, RE TIMELINESS OF CLAIMS ALLEGING DEFECTIVE MORTGAGES UNDERLYING RESIDENTIAL MORTGAGE BACKED SECURITIES, WHERE THE CONTRACT CALLS FOR TIMELY NOTICES OF BREACH, NO NOTICE OF BREACH REQUIRED WHERE DEFENDANT ITSELF DISCOVERS THE DEFECTIVE MORTGAGE)

/ , ,

QUESTION OF FACT WHETHER WORKER’S COMPENSATION LAW PRECLUDED SUIT IN NEGLIGENCE, DEFENDANT WAS BOTH AN OFFICER OF PLAINTIFF’S EMPLOYER AND OWNER, IN AN INDIVIDUAL CAPACITY, OF THE PREMISES WHERE PLAINTIFF SLIPPED AND FELL.

The Third Department, reversing Supreme Court, determined there was a question of fact whether the Workers’ Compensation Law precluded a lawsuit in negligence against the defendant, who was the president and a shareholder of plaintiff’s employer, Total Recall, and was the owner, in an individual capacity, of the building in which Total Recall is located. Plaintiff slipped and fell on ice in the parking lot behind the building:

… [W]hen an employee, during the course of his or her employment, is injured due to the negligence of a coemployee, the employee’s right to compensation lies under the exclusive provisions of the Workers’ Compensation Law (see Workers’ Compensation Law § 29 [6]…). Where the defendant is both the property owner and a corporate officer of the plaintiff’s employer, the defendant’s responsibility to provide the plaintiff with a safe place to work may be merged, in which case, workers’ compensation benefits are the sole remedy for the plaintiff … . If, however, the “defendant’s duty of care toward [the] plaintiff was owed purely in [the] capacity as owner of the property at the accident site, and not at all as a coemployee,” Workers’ Compensation Law § 29 (6) will not bar the plaintiff’s negligence action … .

The issue distills to whether the accident site was in an area that was exclusive to Total Recall and its employees such that defendant, as the property owner and an executive officer of Total Recall, had indistinguishable obligations to maintain the area in a reasonably safe condition. Garelle v Geinitz, 2016 NY Slip Op 08916, 3rd Dept 12-29-16

NEGLIGENCE (QUESTION OF FACT WHETHER WORKER’S COMPENSATION LAW PRECLUDED SUIT IN NEGLIGENCE, DEFENDANT WAS BOTH AN OFFICER OF PLAINTIFF’S EMPLOYER AND OWNER, IN AN INDIVIDUAL CAPACITY, OF THE PREMISES WHERE PLAINTIFF SLIPPED AND FELL)/WORKERS’ COMPENSATION LAW (NEGLIGENCE, QUESTION OF FACT WHETHER WORKER’S COMPENSATION LAW PRECLUDED SUIT IN NEGLIGENCE, DEFENDANT WAS BOTH AN OFFICER OF PLAINTIFF’S EMPLOYER AND OWNER, IN AN INDIVIDUAL CAPACITY, OF THE PREMISES WHERE PLAINTIFF SLIPPED AND FELL)/SLIP AND FALL (QUESTION OF FACT WHETHER WORKER’S COMPENSATION LAW PRECLUDED SUIT IN NEGLIGENCE, DEFENDANT WAS BOTH AN OFFICER OF PLAINTIFF’S EMPLOYER AND OWNER, IN AN INDIVIDUAL CAPACITY, OF THE PREMISES WHERE PLAINTIFF SLIPPED AND FELL)/CORPORATION LAW (QUESTION OF FACT WHETHER WORKER’S COMPENSATION LAW PRECLUDED SUIT IN NEGLIGENCE, DEFENDANT WAS BOTH AN OFFICER OF PLAINTIFF’S EMPLOYER AND OWNER, IN AN INDIVIDUAL CAPACITY, OF THE PREMISES WHERE PLAINTIFF SLIPPED AND FELL)

/ ,

PLAINTIFF’S ACTIONS WERE THE SOLE PROXIMATE CAUSE OF HIS INJURY, NEGLIGENT SUPERVISION CAUSE OF ACTION SHOULD HAVE BEEN DISMISSED AS A MATTER OF LAW, NOTICE OF CLAIM WAS SUFFICIENT NOTIFICATION OF THE NEGLIGENT SUPERVISION CAUSE OF ACTION.

The Third Department, reversing Supreme Court, after finding the notice of claim was sufficient notice of the negligent supervision cause of action, determined the defendant town was entitled to summary judgment dismissing the complaint. Town workers were in the process of delivering a load of wood chips to plaintiff. When the wood chips stopped flowing from the dump truck, plaintiff attempted to free the chips by slamming the tailgate. Plaintiff's thumb and wrist were crushed by the tailgate. Although plaintiff alleged that he called out to the driver (Klopfer) to ask if he should slam the tailgate, there was no response. The Third Department found plaintiff's unilateral decision to slam the tailgate was the sole proximate cause of his injury:

The dispute centers on whether defendant owed a duty of care to plaintiff and, if so, whether defendant's breach of duty was a proximate cause of plaintiff's injuries. From a general perspective, we recognize that Klopfer had a duty to exercise reasonable care in the operation of a municipal dump truck. Moreover, Klopfer was certainly aware of plaintiff's presence during the unloading process. That said, the Court of Appeals has emphasized a “reluctance to extend liability to a defendant for failure to control the conduct of others” … . By his testimony, plaintiff confirmed that he acted of his own accord, slamming the tailgate twice within only a few seconds, providing little if any opportunity for Klopfer to respond — even if he heard plaintiff call out … . There was no defect in the tailgate and the risk of injuring one's hand when slamming a tailgate is obvious as a matter of common sense. No resident, including plaintiff, had ever previously attempted to intervene in the discharge process and, while [a second town worker] had stepped away, plaintiff knew he was on site and could have sought his assistance. Under these circumstances, we conclude that plaintiff's intervening action in slamming the tailgate was the sole proximate cause of his injuries … . Barone v Town of New Scotland, 2016 NY Slip Op 08927, 3rd Dept 12-29-16

NEGLIGENCE (PLAINTIFF'S ACTIONS WERE THE SOLE PROXIMATE CAUSE OF HIS INJURY, NEGLIGENT SUPERVISION CAUSE OF ACTION SHOULD HAVE BEEN DISMISSED AS A MATTER OF LAW)/MUNICIPAL LAW (NOTICE OF CLAIM WAS SUFFICIENT NOTIFICATION OF THE NEGLIGENT SUPERVISION CAUSE OF ACTION)/NOTICE OF CLAIM (NOTICE OF CLAIM WAS SUFFICIENT NOTIFICATION OF THE NEGLIGENT SUPERVISION CAUSE OF ACTION)/PROXIMATE CAUSE (PLAINTIFF'S ACTIONS WERE THE SOLE PROXIMATE CAUSE OF HIS INJURY, NEGLIGENT SUPERVISION CAUSE OF ACTION SHOULD HAVE BEEN DISMISSED AS A MATTER OF LAW)/NEGLIGENT SUPERVISION (PLAINTIFF'S ACTIONS WERE THE SOLE PROXIMATE CAUSE OF HIS INJURY, NEGLIGENT SUPERVISION CAUSE OF ACTION SHOULD HAVE BEEN DISMISSED AS A MATTER OF LAW, NOTICE OF CLAIM WAS SUFFICIENT NOTIFICATION OF THE NEGLIGENT SUPERVISION CAUSE OF ACTION)

/

AUTHORIZATION TO FORCE FEED INMATE FOR THE DURATION OF HIS INCARCERATION PROPERLY GRANTED.

The Third Department affirmed the grant of a petition by the prison warden authorizing the force feeding of an inmate for the duration of his incarceration:

When an inmate commences a hunger strike, which, if continued, would create a substantial risk of imminent death or serious permanent injury, a force-feeding order is warranted if the state’s intervention, even if contrary to the inmate’s constitutional rights, is reasonably related to its legitimate penological interests, including those in preserving the inmate’s life and maintaining safety and discipline within the facility (see Matter of Bezio v Dorsey, 21 NY3d 93, 99, 101-107 [2013]). The record shows that respondent had repeatedly engaged in hunger strikes since May 2013 with the stated purpose of obtaining a transfer to a maximum A security facility, and that respondent had stated that he would continue his hunger strike until he died or was transferred. …

We look no further than the holding in Matter of Bezio v Dorsey (supra) to reach the conclusion that the state’s interest in preserving respondent’s life outweighs any claimed infringement of respondent’s constitutional rights. On the record before us, Supreme Court properly issued a force-feeding order for the duration of respondent’s incarceration. Matter of Martuscello v Jua TT., 2016 NY Slip Op 08905, 3rd Dept 12-29-16

 

INVOLUNTARY MEDICAL TREATMENT AND FEEDING (INMATES) (AUTHORIZATION TO FORCE FEED INMATE FOR THE DURATION OF HIS INCARCERATION PROPERLY GRANTED)/INMATES (INVOLUNTARY MEDICAL TREATMENT AND FEEDING, AUTHORIZATION TO FORCE FEED INMATE FOR THE DURATION OF HIS INCARCERATION PROPERLY GRANTED)

/ , ,

INSURER OF COMPANY UNDER CONTRACT TO MAINTAIN STREET LIGHTING AND TRAFFIC CONTROL DEVICES HAD A DUTY TO DEFEND THE CITY IN PERSONAL INJURY SUITS ALLEGING INADEQUATE LIGHTING AND MALFUNCTIONING TRAFFIC CONTROL DEVICES.

INSURANCE LAW, MUNICIPAL LAW, NEGLIGENCE.

In a decision too lengthy and fact-specific to fairly summarize here, the First Department determined whether the insurance company which insured a company that maintained street lighting and traffic control devices under a contract with the Bronx had a duty to defend against personal injury suits brought against New York City.  The city was named an additional insured in the policies. . The personal injury suits alleged improper street lighting, malfunctioning traffic control devices, and, in one case, injury from a falling traffic control device. A duty to defend was found in four of the five lawsuits. The court explained the applicable law as follows:

On a summary judgment motion in a case involving an insurance contract or policy, “[t]he evidence will be construed in the light most favorable to the one moved against” … . The insured, however, has the burden of showing that an insurance contract covers the loss for which the claim is made … .

The applicable standard holds that the duty to defend arises when at least one of two alternate criteria are met. “A duty to defend exists whenever the allegations in the complaint in the underlying action, construed liberally, suggest a reasonable possibility of coverage, or where the insurer has actual knowledge of facts establishing such a reasonable possibility” … . City of New York v Wausau Underwriters Ins. Co., 2016 NY Slip Op 08932, 1st Dept 12-29-16

 

INSURANCE LAW (INSURER OF COMPANY UNDER CONTRACT TO MAINTAIN STREET LIGHTING AND TRAFFIC CONTROL DEVICES HAD A DUTY TO DEFEND THE CITY IN PERSONAL INJURY SUITS ALLEGING INADEQUATE LIGHTING AND MALFUNCTIONING TRAFFIC CONTROL DEVICES)/MUNICIPAL LAW (INSURER OF COMPANY UNDER CONTRACT TO MAINTAIN STREET LIGHTING AND TRAFFIC CONTROL DEVICES HAD A DUTY TO DEFEND THE CITY IN PERSONAL INJURY SUITS ALLEGING INADEQUATE LIGHTING AND MALFUNCTIONING TRAFFIC CONTROL DEVICES)/NEGLIGENCE (INSURANCE LAW, MUNICPAL LAW, NSURER OF COMPANY UNDER CONTRACT TO MAINTAIN STREET LIGHTING AND TRAFFIC CONTROL DEVICES HAD A DUTY TO DEFEND THE CITY IN PERSONAL INJURY SUITS ALLEGING INADEQUATE LIGHTING AND MALFUNCTIONING TRAFFIC CONTROL DEVICES)/DUTY TO DEFEND (INSURANCE LAW, INSURER OF COMPANY UNDER CONTRACT TO MAINTAIN STREET LIGHTING AND TRAFFIC CONTROL DEVICES HAD A DUTY TO DEFEND THE CITY IN PERSONAL INJURY SUITS ALLEGING INADEQUATE LIGHTING AND MALFUNCTIONING TRAFFIC CONTROL DEVICES)/STREET LIGHTING (INSURER OF COMPANY UNDER CONTRACT TO MAINTAIN STREET LIGHTING AND TRAFFIC CONTROL DEVICES HAD A DUTY TO DEFEND THE CITY IN PERSONAL INJURY SUITS ALLEGING INADEQUATE LIGHTING AND MALFUNCTIONING TRAFFIC CONTROL DEVICES)/TRAFFIC CONTROL DEVICES  (INSURER OF COMPANY UNDER CONTRACT TO MAINTAIN STREET LIGHTING AND TRAFFIC CONTROL DEVICES HAD A DUTY TO DEFEND THE CITY IN PERSONAL INJURY SUITS ALLEGING INADEQUATE LIGHTING AND MALFUNCTIONING TRAFFIC CONTROL DEVICES)/HIGHWAYS AND ROADS  (INSURER OF COMPANY UNDER CONTRACT TO MAINTAIN STREET LIGHTING AND TRAFFIC CONTROL DEVICES HAD A DUTY TO DEFEND THE CITY IN PERSONAL INJURY SUITS ALLEGING INADEQUATE LIGHTING AND MALFUNCTIONING TRAFFIC CONTROL DEVICES)

/ ,

DAMAGES UNDER THE FAIR CREDIT REPORTING ACT ARE NOT PENALTIES, INSURANCE POLICY EXCLUSION OF COVERAGE FOR PENALTIES DID NOT APPLY.

The First Department rejected plaintiff insurer’s argument that it was not required to pay the cost of its insured’s settlement of a class action claim under the Fair Credit Reporting Act (FCRA) because the settlement constituted a penalty (not covered by the policy) rather than compensatory damages:

To make out a claim under the FCRA (15 USC § 1681 et seq. ), the complaint must allege, inter alia, injury in fact, a “concrete and particularized” and “actual or imminent” “invasion of a legally protected interest,” i.e., the statutory right to the fair handling of the plaintiff consumer’s credit information … . The remedy for “willful” failure to comply with a requirement of the statute is “any actual damages sustained by the consumer by the failure or damages of not less than $100 and not more than $1,000,” and “such amount of punitive damages as the court may allow,” as well as costs and reasonable attorneys’ fees … . Since the consumer must elect the option of either actual or statutory damages, and may also recover punitive damages, it is reasonable to infer, as the motion court did, that the actual and the statutory damages serve the same purpose … . Moreover, the statute provides separately for a civil penalty (recoverable by the Federal Trade Commission) … . Plaintiff argues that the limitation of damages to a “willful” violation of the statute evinces a legislative intent to penalize intentional misconduct, rather than compensate for actual damages sustained, but this is not so, since willfulness as a statutory condition of civil liability “cover[s] not only knowing violations of a standard, but reckless ones as well” … . Thus, it is clear that Congress intended the statutory damages provided for by the FCRA to be compensatory and not a penalty … . Navigators Ins. Co. v Sterling Infosystems, Inc., 2016 NY Slip Op 08941, 1st Dept 12-29-16

INSURANCE LAW (DAMAGES UNDER THE FAIR CREDIT REPORTING ACT IS NOT A PENALTY, INSURANCE POLICY EXCLUSION OF COVERAGE OF PENALTIES DID NOT APPLY)/FAIR CREDIT REPORTING ACT (FRCA) (INSURANCE LAW, DAMAGES UNDER THE FAIR CREDIT REPORTING ACT IS NOT A PENALTY, INSURANCE POLICY EXCLUSION OF COVERAGE OF PENALTIES DID NOT APPLY)

/

DENIAL OF FREEDOM OF INFORMATION LAW REQUESTS REVERSED, CASE REMITTED TO DETERMINE IF REDACTION CAN ADEQUATLEY PROTECT PRIVACY.

The Third Department, reversing Supreme Court, determined that the requests for information about former public employees who applied for positions in state college police departments should not have been denied. The argument that redaction of identifying information from the documents (to which petitioner agreed) would not protect the applicants’ privacy was rejected. The matter was remitted for court review of the documents:

… [R]espondents argue — and Supreme Court agreed — that, given the prominent nature of the positions and the limited number of applicants, disclosure of the requested documents, even with appropriate redactions, could lead to the identification of the unsuccessful applicants. Such speculation, however, “does not rise to the level of ‘a particularized and specific justification for denying access’ to the [entirety of] the records requested” … . Respondents have failed to demonstrate any factual basis for their assertion that the requested documents cannot be redacted in such a manner as to protect the identity of the individual applicants … . …

… [T]he matter must be remitted to Supreme Court for an in camera inspection of the requested documents to determine the extent to which they contain information exempt from disclosure and whether such information can be redacted while still protecting the personal privacy of those individuals … . Matter of Police Benevolent Assn. of N.Y. State, Inc. v State of New York, 2016 NY Slip Op 08918 3rd Dept 12-29-16

 

FREEDOM OF INFORMATION LAW (FOIL) (DENIAL OF FREEDOM OF INFORMATION LAW REQUESTS REVERSED, CASE REMITTED TO DETERMINE IF REDACTION CAN ADEQUATLEY PROTECT PRIVACY)

Categories

Sign Up for the Mailing List to Be Notified When the Site Is Updated.

  • This field is for validation purposes and should be left unchanged.

Copyright © 2026 New York Appellate Digest, Inc.
Site by CurlyHost | Privacy Policy