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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

Morris v. United Parcel Service

Plaintiff, a former United Parcel Service employee and union member, was discharged for alleged theft after being accused of stealing a package of watches. Although he was arrested, he was later acquitted of petit larceny. An arbitrator subsequently found his discharge was not for just cause and ordered his reinstatement with back pay and benefits. Following this, the plaintiff commenced an action against United Parcel Service for false imprisonment/unlawful arrest. Defendants moved for summary judgment, arguing preemption by the Labor Management Relations Act and the National Labor Relations Act, and sought to add affirmative defenses. Special Term denied summary judgment but granted leave to amend the answer. The appellate court affirmed the denial of summary judgment, concluding the tort claim was not preempted, but found that Special Term erred in refusing to dismiss the defendants' affirmative defenses regarding federal preemption and the exclusivity of Workers' Compensation Law § 11.

False ImprisonmentUnlawful ArrestLabor Management Relations Act PreemptionNational Labor Relations Act PreemptionCollective Bargaining AgreementWorkers' Compensation LawExclusive Remedy ProvisionSummary JudgmentAppellate ReviewTort Claim
References
7
Case No. MISSING
Regular Panel Decision
May 20, 1993

Ray v. Metropolitan Transportation Authority

Larry Ray, a maintenance worker, and Blake Willett, an LIRR Police Officer, were involved in a physical altercation where Willett allegedly beat and handcuffed Ray. Ray was later released by Willett's supervisor. Plaintiffs sued Willett and the Long Island Rail Road (LIRR) for battery, false arrest and imprisonment, negligent retention, and civil rights violations under 42 USC § 1983. The Supreme Court, Kings County, dismissed claims against the LIRR for negligent retention and civil rights violations and dismissed the complaint against Willett due to defective service of process. The jury found Willett liable for battery and false arrest/imprisonment but not for civil rights violation. The appellate court affirmed the judgment, finding no error in the dismissals, concluding that Willett's conduct was not within the scope of employment and he was not acting under color of state law, and that service upon Willett was indeed defective.

BatteryFalse ImprisonmentCivil Rights ViolationNegligent RetentionRespondeat SuperiorPolice MisconductPersonal JurisdictionService of ProcessAppellate LawKings County
References
17
Case No. MISSING
Regular Panel Decision

Sankar v. City of New York

This case involves a landlord (plaintiff) who faced two arrests in 2006 based on allegedly false police reports filed by her tenant, Karlene White, stemming from a landlord-tenant dispute. The plaintiff subsequently sued White, several police officers, an assistant district attorney, and the City of New York for federal and state law claims including false arrest, malicious prosecution, and battery. The court granted in part and denied in part the defendants' motion for summary judgment. Claims for false arrest against Officers Ostrowski and Galli, malicious prosecution against Officer Ostrowski, and battery against Ostrowski and Galli (all in their individual capacities) survived summary judgment. Additionally, state law claims for false arrest, malicious prosecution, and battery against the City of New York under respondeat superior liability were also denied summary judgment. All other claims, including those related to a November arrest, claims against other named defendants, and intentional infliction of emotional distress, were dismissed.

false arrestmalicious prosecutioncivil rightspolice misconductprobable causequalified immunitymunicipal liabilityrespondeat superiorbatterylandlord-tenant dispute
References
51
Case No. MISSING
Regular Panel Decision

Harris v. County of Nassau

Plaintiff Martin Harris filed a civil rights lawsuit under 42 U.S.C. §§ 1983, 1985, and 1986, alleging false arrest, false imprisonment, and malicious prosecution following his February 2006 arrest and subsequent acquittal. He sued the County of Nassau, the Village of Hempstead, the Village of Hempstead Police Department, Detectives James Hendry and Gerard Giambruno, Police Officer Edward A. Matalone, and an Assistant District Attorney Ci-accio. Defendants moved to dismiss the complaint. The court granted the motion, finding probable cause for Harris's arrest, thus barring claims for false arrest, false imprisonment, and malicious prosecution. The court also held that officers were protected by qualified immunity and the Assistant District Attorney by prosecutorial immunity. Other claims for due process, equal protection, and conspiracy were dismissed for lack of factual support. With all federal claims dismissed, the court declined supplemental jurisdiction over state law claims, dismissing the complaint in its entirety.

Civil RightsFalse ArrestFalse ImprisonmentMalicious ProsecutionQualified ImmunityProsecutorial ImmunityMunicipal LiabilityProbable CauseDue ProcessEqual Protection
References
49
Case No. MISSING
Regular Panel Decision
Oct 24, 2014

Guzman v. Jay

Plaintiff Noel Jackson Guzman filed a Section 1983 action against New York City Police Officer Brian Jay, alleging false arrest and excessive force stemming from a 2009 incident. A jury trial resulted in a verdict for Guzman, awarding him significant compensatory and punitive damages for false arrest and excessive force. Officer Jay subsequently moved for a new trial, remittitur, and judgment as a matter of law. The court denied motions for a new trial and remittitur, but granted judgment as a matter of law on the false arrest claim due to qualified immunity. This decision was based on the jury's finding that Officer Jay reasonably, though possibly mistakenly, believed Guzman was fighting at the time of arrest.

False ArrestExcessive Force42 U.S.C. § 1983Qualified ImmunityJury VerdictRemittiturNew Trial MotionJudgment as a Matter of LawPolice MisconductPersonal Injury
References
43
Case No. MISSING
Regular Panel Decision

Johnson v. City of New York

Steven M. Johnson and his wife Rebecca Guzman Johnson brought an action under 42 U.S.C. § 1983 and New York State law against the City of New York, former Police Commissioner Raymond W. Kelly, and New York City Police Officers Dorothy Werkmeister, John Polis, and Sergeant Julio Ordonez. Johnson alleged false arrest, malicious prosecution, and excessive force after being arrested based on a warrant for a different individual, despite significant physical description discrepancies. He was detained and handcuffed, reportedly too tightly, before being released by a judge who confirmed his identity. The court granted summary judgment for defendants on Johnson's Section 1983 claims for malicious prosecution and excessive force, and dismissed all claims against the City, Kelly, and Rebecca Guzman Johnson. However, summary judgment was denied for Johnson's Section 1983 false arrest claim and his state law claims for false arrest, malicious prosecution, and assault and battery.

Section 1983False ArrestMalicious ProsecutionExcessive ForceQualified ImmunitySummary JudgmentMunicipal LiabilityPolice MisconductConstitutional RightsFourth Amendment
References
29
Case No. 97 Civ. 9770
Regular Panel Decision

Richards v. CITY OF NEW YORK 405

Samantha Richards and her children sued the City of New York, law enforcement personnel, the Administration of Children's Services (ACS), and Little Flower Children's Services (LFCS) for civil rights violations under 42 U.S.C. § 1983, including false arrest, malicious prosecution, and the wrongful removal and failure to protect the children in foster care. Plaintiffs also brought state law claims for breach of contract, social work malpractice, trespass, false arrest, false imprisonment, intentional and negligent infliction of emotional distress, conversion of property, and conspiracy. The court granted summary judgment in part, dismissing § 1983 claims against detectives McCann and Paul for false arrest and child removal based on qualified immunity, all § 1983 claims against ACS and LFCS for lack of deliberate indifference or inadequate training, and various state law claims due to pleading deficiencies or lack of evidence. Claims for malicious prosecution against McCann and Paul, and certain state law claims against the City of New York, remain.

42 U.S.C. § 1983False ArrestMalicious ProsecutionChild Custody DeprivationFailure to ProtectQualified ImmunitySummary JudgmentFoster Care NegligenceDeliberate IndifferenceInadequate Training
References
52
Case No. MISSING
Regular Panel Decision

Nazarian v. Compagnie Nationale Air France

Plaintiffs, Iranian nationals Kamran and Faranak Nazarian, purchased Air France tickets for travel from New York to Athens via Paris. Their return flight was delayed, causing them to miss their connection in Paris. An Air France manager took their passports and tickets to secure temporary visas for an overnight stay but left them at immigration. French officials denied their visas due to their nationality, arrested them, and detained them without food or drink, and subjected them to assault. The Nazarians sued Air France for negligence, false imprisonment, false arrest, intentional infliction of emotional distress, and breach of express promise. The court dismissed claims for false imprisonment, false arrest, intentional infliction of emotional distress, and breach of express promise due to lack of subject matter jurisdiction under the Foreign Sovereign Immunities Act. However, the court retained jurisdiction over the negligence claim concerning the Air France manager's conduct in Paris, based on a duty of care established by the ticket purchase in the U.S. Negligence claims related to flight schedule were preempted by the Airline Deregulation Act.

Foreign Sovereign Immunities ActCommercial Activity ExceptionSubject Matter JurisdictionNegligenceAirline LiabilityFalse ImprisonmentFalse ArrestIntentional Infliction of Emotional DistressBreach of PromiseAirline Deregulation Act
References
22
Case No. MISSING
Regular Panel Decision

Levantino v. New York State Police

Plaintiff Michael J. Levantino filed a § 1983 action against New York State Police and individual state troopers (Keith M. Skala, John Doe #1, and John Doe #2) alleging false arrest, false imprisonment, and violations of his due process and equal protection rights. These claims arose from an arrest for suspected marijuana cultivation, where he was allegedly subjected to a warrantless search, handcuffed, interrogated without Miranda rights, and detained for almost 24 hours without probable cause, only for charges to be dismissed when evidence showed he was wrongly identified. Defendants moved to dismiss, and Plaintiff cross-moved to amend the complaint, seeking to remove certain defendants and claims while adding others. The court denied the motion to dismiss as moot and granted in part and denied in part the plaintiff's cross-motion to amend, allowing claims for false arrest, false imprisonment, deliberate delay of paperwork (procedural due process), and unlawful search/seizure against Skala and Horgan (who replaced John Doe #1) in their individual capacities to proceed. Other claims, including prima facie tort and claims against John Doe #2 and the New York State Police, were denied or terminated.

False ArrestFalse Imprisonment42 U.S.C. § 1983Fourth Amendment ViolationProcedural Due ProcessQualified Immunity DefenseMotion to DismissMotion to Amend ComplaintIllegal Search and SeizureProbable Cause
References
67
Case No. 14-CV-6459
Regular Panel Decision

Watson v. United States

Davino Watson, an American citizen, was wrongly arrested and detained by government immigration officials for 1,273 days, mistakenly identified as an alien. The court found that negligent investigation by ICE officers led to his initial false arrest and imprisonment. While his detention became legally privileged after 27 days due to a change in BIA interpretation of Jamaican legitimation law, the government was held liable for the initial period. The court awarded Watson $82,500 in damages for false arrest and 27 days of false imprisonment, highlighting the critical need for legal counsel in immigration cases to prevent such injustices.

False ArrestFalse ImprisonmentImmigration LawCitizenshipFederal Tort Claims ActNegligenceDue ProcessAdministrative ErrorConstitutional RightsDamages
References
64
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