Matter of Curry v. Commissioner of N.Y. State Dept. of Motor Vehicles
In Matter of Curry v Commissioner of N.Y. State Dept. of Motor Vehicles, petitioner Joseph P. Curry appealed a judgment dismissing his CPLR article 78 petition. Curry's driver's license was revoked in 2012 due to a fifth alcohol-related driving offense. His 2017 application for relicensing and a hardship exception was denied by the Department of Motor Vehicles' Driver Improvement Bureau and affirmed by the Administrative Appeals Board. Curry challenged this denial as arbitrary and capricious, citing rehabilitation efforts and medical needs for a license. The Appellate Division, Third Department, affirmed the Supreme Court's dismissal, finding the Commissioner's denial was not arbitrary or capricious given Curry's history of multiple relapses, traffic infractions, and an incomplete DWI evaluation, despite his claims of sobriety and medical appointments.