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Case Law Database

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

Case No. 13-CV-7588 (RWS)

Regular Panel Decision

Apr 09, 2014

New York State Court Clerks Ass'n v. Unified Court System

The New York State Court Clerks Association and Monica Shaw Burns filed a lawsuit against several New York State Judges, the Unified Court System (UCS), and the Office of Court Administration (OCA), alleging violations of the Fair Labor Standards Act (FLSA) due to uncompensated overtime work. The defendants moved to dismiss the amended complaint, citing Eleventh Amendment sovereign immunity. The court granted the motions, ruling that the Eleventh Amendment bars claims against UCS, OCA, and the State Judges in their official capacities, as Congress did not abrogate state sovereign immunity under the FLSA. The court also found that plaintiffs failed to adequately allege that the State Judges were 'employers' under the FLSA's 'economic reality' test, and that employees cannot seek injunctive relief under FLSA. Consequently, the amended complaint was dismissed with prejudice.

Overtime WagesFair Labor Standards ActEleventh Amendment ImmunitySovereign ImmunityDeclaratory Judgment ActMotion to DismissSubject Matter JurisdictionState Judicial OfficialsOfficial Capacity SuitEconomic Reality Test

References

Case No. MISSING

Regular Panel Decision

Koerner v. State of New York

A plaintiff was terminated from a state psychiatric center position in 1981 due to poor vision, which they claimed did not impair their work ability. They filed a lawsuit in 1982, alleging physical disability discrimination by the State under the Human Rights Law, seeking reinstatement, back pay, and damages. Lower courts dismissed the complaint, ruling it was time-barred by a four-month statute of limitations and that monetary claims against the State belonged exclusively in the Court of Claims. The Court of Appeals reversed, establishing that a three-year statute of limitations applies to Human Rights Law actions against the State. The court further held that the Legislature implicitly waived the State's immunity to suit in forums other than the Court of Claims for such discrimination cases, allowing for both equitable and monetary relief in appropriate courts.

Human Rights LawStatute of LimitationsCPLR 217CPLR 214Court of ClaimsSovereign ImmunityDiscriminatory DischargePhysical Disability DiscriminationState as EmployerEquitable Relief

References

Case No. MISSING

Regular Panel Decision

United States v. State of New York

The United States sued the State of New York and several state entities, including SBOE, SUNY, and CUNY, alleging violations of the National Voter Registration Act of 1993 (NVRA). The core issue was whether state-funded Disabled Student Services (DSS) offices at public colleges and universities, including SUNY and CUNY campuses and community colleges, must be designated as mandatory voter registration agencies (VRAs) under 42 U.S.C. § 1973gg-5(a)(2)(B). The State defendants argued these offices were not 'primarily engaged' in serving persons with disabilities, and that the NVRA did not apply to them. The Court rejected the defendants' arguments regarding subject matter jurisdiction and the interpretation of the NVRA, citing legislative intent and prior circuit court decisions. The Court concluded that DSS offices at all SUNY and CUNY campuses and their respective community colleges are indeed state-funded programs primarily engaged in providing services to persons with disabilities, and therefore must be designated as mandatory VRAs. The plaintiff's motion for summary judgment was granted.

National Voter Registration Act (NVRA)Voter Registration Agencies (VRAs)Disabled Student Services (DSS)State-funded programsPublic universitiesCommunity collegesFederalismSummary judgmentDeclaratory reliefInjunctive relief

References

Case No. MISSING

Regular Panel Decision

Koffman v. State

Claimant leased the first floor of a building to the State in Binghamton. The State's Department expanded to the second floor, with claimant undertaking renovations for which reimbursement was expected. After the original lease expired, negotiations for a new lease covering both floors failed, and the State refused to pay rent for the second floor space or for the renovations. The claimant, acting through representatives due to a legal disability, filed a claim against the State for unpaid rent and renovation costs. The Court of Claims found the claim timely but dismissed the causes of action related to the second-floor rent and renovations, citing State Finance Law § 112 (2). The appellate court affirmed this decision, holding that the State Finance Law barred recovery for contracts exceeding $5,000 without Comptroller approval, and principles of equitable estoppel against the State were not applicable.

Lease AgreementState ContractsEquitable EstoppelImplied ContractLegal DisabilityStatute of LimitationsCourt of Claims ActState Finance LawUnjust EnrichmentTenant at Will

References

Case No. MISSING

Regular Panel Decision

Levine v. State

The claimant, a CETA employee of Ulster County, was awarded a judgment against the State for its negligent failure to protect her from a physical assault and rape at the Highland State Training School. She had previously received workers' compensation benefits for her injuries. On appeal, the State argued for the first time that the claimant was its "special employee" and thus the workers' compensation exclusivity doctrine barred the action, divesting the Court of Claims of jurisdiction. The court affirmed the judgment, ruling that the State had waived this defense due to its "inordinate and inexcusable delay" in raising the issue over four years and a bifurcated trial, causing operative prejudice to the claimant. This decision aligns with precedent established in *Shine v Duncan Petroleum Transp.* regarding waiver of such defenses.

Workers' Compensation ExclusivitySpecial Employee DoctrineWaiver of DefenseOperative PrejudiceCourt of Claims JurisdictionNegligent ProtectionPhysical AssaultRape IncidentCETA EmployeeAppellate Process

References

Case No. 2017 NY Slip Op 08595 [156 AD3d 1043]

Regular Panel Decision

Dec 07, 2017

New York State Workers' Compensation Board v. Any-Time Home Care Inc.

The New York State Workers' Compensation Board, acting as administrator for a dissolved self-insured trust, initiated an action to recover a $133 million cumulative deficit from former trust members. Various defendants sought to dismiss the complaint, asserting claims were time-barred by a three-year statute of limitations for statutory liabilities, failed to adequately state claims against individual partners, and were barred by the doctrine of laches. The Supreme Court denied these motions. On appeal, the Appellate Division, Third Department, affirmed the Supreme Court's order, ruling that the claims were contractual, subject to a six-year limitation period, and that laches did not apply against the state enforcing a public right. The court also found the complaint sufficiently specific regarding the liability of individual defendants.

Workers' Compensation LawSelf-Insurance TrustJoint and Several LiabilityStatute of LimitationsContractual LiabilityLaches DoctrineAppellate ReviewGroup Self-InsurerDeficit RecoveryPartnership Liability

References

Case No. MISSING

Regular Panel Decision

Maurer v. State Emergency Management Office

This CPLR article 78 proceeding involved petitioners seeking mandamus relief to compel state respondents to grant them the same retroactive overtime cap relief afforded to petitioners in Matter of Neary v New York State Div. of Budget. Petitioners, including Donald Maurer, argued they were "similarly situated" and thus entitled to relief despite not commencing timely certiorari proceedings, which were now time-barred. The court, presided over by James B. Canfield, J., rejected this argument, asserting that article 78 decisions apply prospectively and do not revive dead cases or create new causes of action for similarly situated individuals who failed to act within the statute of limitations. The court found that the challenge to the overtime cap was time-barred, as petitioners were aggrieved and put on notice when they received capped overtime pay, well before the proceeding's commencement on January 24, 2003. Consequently, the petition was dismissed, and all requested relief was denied.

MandamusArticle 78 ProceedingStatute of LimitationsOvertime PayProspective ApplicationRetroactive ApplicationClass Action EquivalenceState EmployeesAdministrative DeterminationsTimeliness

References

Case No. MISSING

Regular Panel Decision

Bounds v. State

The case involves an appeal concerning a claimant injured while participating in the Work Experience Program (WEP) at Cayuga Lake State Park, subsequently suing the State of New York under Labor Law § 240 (1). The initial Court of Claims decision granted partial summary judgment to the claimant. However, the appellate court determined that while the claimant was an employee of Seneca County, a triable issue of fact existed regarding whether he was also a 'special employee' of the State of New York. This 'special employee' status is crucial as it could invoke the exclusive remedy provisions of the Workers' Compensation Law, thereby barring his claim. Consequently, the appellate court modified the judgment by denying both the claimant's motion for partial summary judgment and the defendant's cross-motion for summary judgment, affirming the judgment as modified.

Workers' CompensationSpecial EmployeeLabor LawScaffolding AccidentSummary JudgmentAppellate ReviewPublic AssistanceWork Experience ProgramEmployer LiabilityStatutory Interpretation

References

Case No. MISSING

Regular Panel Decision

Feb 25, 2004

Hom v. Brennan

Plaintiff George Horn, proceeding pro se, initiated an action in New York State Supreme Court, Nassau County, alleging that various defendants, including judges and state officials, deprived him of his civil rights under 42 U.S.C. § 1983. The case was subsequently removed to the Eastern District of New York. Horn's motion to remand the action back to state court was denied. The court granted defendant Lois Grossman's motion to dismiss for failure to state a claim, ruling that she was not a state actor for Section 1983 purposes and the conspiracy allegations were insufficient. Additionally, the plaintiff filed six separate motions to supplement his complaint to add new defendants and claims, all of which were denied due to judicial immunity for the proposed judicial defendants, the Rooker-Feldman doctrine barring review of state court decisions, or the futility of the proposed claims.

Civil RightsSection 1983Pro Se LitigationJudicial ImmunityRooker-Feldman DoctrineMotion to RemandMotion to DismissSupplemental PleadingsFederal JurisdictionState Actor

References

Case No. MISSING

Regular Panel Decision

Hale v. New York State Department of Mental Health

Curtis Hale, Jr. initiated an action under Title VII, alleging racial discrimination after his termination as a Mental Hygiene Therapy Aide at the Bronx Children’s Psychiatric Center. He claimed the Civil Service Employee Association failed to provide adequate representation and the New York State Department of Mental Health breached contractual obligations. The court, treating the State's motion to dismiss as one for summary judgment, found Hale's Title VII claims time-barred. His EEOC complaint was filed beyond the 180 or 300-day statutory limitations period, which commenced from the notice of termination (December 8, 1978), not the actual discharge date. Additionally, the court determined it lacked subject-matter jurisdiction over Hale’s state law breach of contract claim against the State, citing an absence of diversity and no federal question under the Labor Management Relations Act. Consequently, the court granted the State’s motion, dismissing the complaint against the New York State Department of Mental Health.

Racial DiscriminationTitle VIIEmployment TerminationStatute of LimitationsSummary JudgmentBreach of ContractSubject Matter JurisdictionPendent JurisdictionEleventh AmendmentCivil Service

References

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Updated Daily

Case Law Database

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

Case No. 13-CV-7588 (RWS)

Regular Panel Decision

Apr 09, 2014

New York State Court Clerks Ass'n v. Unified Court System

References

Case No. MISSING

Regular Panel Decision

Koerner v. State of New York

Human Rights LawStatute of LimitationsCPLR 217CPLR 214Court of ClaimsSovereign ImmunityDiscriminatory DischargePhysical Disability DiscriminationState as EmployerEquitable Relief

References

Case No. MISSING

Regular Panel Decision

United States v. State of New York

References

Case No. MISSING

Regular Panel Decision

Koffman v. State

Lease AgreementState ContractsEquitable EstoppelImplied ContractLegal DisabilityStatute of LimitationsCourt of Claims ActState Finance LawUnjust EnrichmentTenant at Will

References

Case No. MISSING

Regular Panel Decision

Levine v. State

References

Case No. 2017 NY Slip Op 08595 [156 AD3d 1043]

Regular Panel Decision

Dec 07, 2017

New York State Workers' Compensation Board v. Any-Time Home Care Inc.

References

Case No. MISSING

Regular Panel Decision

Maurer v. State Emergency Management Office

MandamusArticle 78 ProceedingStatute of LimitationsOvertime PayProspective ApplicationRetroactive ApplicationClass Action EquivalenceState EmployeesAdministrative DeterminationsTimeliness

References

Case No. MISSING

Regular Panel Decision

Bounds v. State

Workers' CompensationSpecial EmployeeLabor LawScaffolding AccidentSummary JudgmentAppellate ReviewPublic AssistanceWork Experience ProgramEmployer LiabilityStatutory Interpretation

References

Case No. MISSING

Regular Panel Decision

Feb 25, 2004

Hom v. Brennan

Civil RightsSection 1983Pro Se LitigationJudicial ImmunityRooker-Feldman DoctrineMotion to RemandMotion to DismissSupplemental PleadingsFederal JurisdictionState Actor

References

Case No. MISSING

Regular Panel Decision

Hale v. New York State Department of Mental Health

Racial DiscriminationTitle VIIEmployment TerminationStatute of LimitationsSummary JudgmentBreach of ContractSubject Matter JurisdictionPendent JurisdictionEleventh AmendmentCivil Service

References

Showing 1-10 of 24,117 results

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