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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
May 26, 2000

Snyder v. Barnhart

Sharon Snyder applied for Supplemental Security Income disability benefits due to severe back pain and carpal tunnel syndrome, which was denied by the Commissioner of Social Security. The Administrative Law Judge (ALJ) found Snyder capable of "medium" work, but not her past work as a maid, and deemed her ineligible for benefits. This decision was affirmed by the Appeals Council. On appeal, the Court found the ALJ erred by not waiting for a detailed response from Snyder's treating physician, Dr. Richard Dobson, regarding her condition and Spinoscope test results, thus failing to fully develop the record. The case is remanded for the ALJ to consider this additional medical information, carefully weigh the treating physician's opinion, reassess Snyder's residual functional capacity (RFC), and re-evaluate her credibility concerning subjective complaints of pain.

Social Security DisabilityChronic Back PainCarpal Tunnel SyndromeSpinoscope TestAdministrative Law JudgeResidual Functional CapacityTreating Physician RuleCredibility AssessmentRemandMedical Evidence
References
12
Case No. MISSING
Regular Panel Decision

Alvarez v. Snyder

This case involves an appeal by plaintiffs from a Supreme Court order dismissing their civil rights complaint, brought under 42 USC § 1983. The plaintiffs, pretrial detainees and their mothers, sought damages for alleged constitutional violations, including infringements on freedom of association and speech, and deprivation of liberty without due process, stemming from 'lock down' orders issued by Justice Leslie Snyder. Justice Snyder, presiding over the detainees' criminal trials, appointed social worker Hillel Bodek as a special master, whose actions were also challenged. The lower court dismissed the complaint based on judicial and quasi-judicial immunity. The appellate court affirmed the dismissal, holding that both Justice Snyder and Bodek were protected by absolute immunity, as their actions were performed within judicial capacity and supported by the court's inherent power to ensure the integrity of its proceedings.

Judicial ImmunityCivil Rights42 USC 1983Pretrial DetaineesFreedom of AssociationFreedom of SpeechDue ProcessSpecial MasterAbsolute ImmunityQuasi-judicial Immunity
References
33
Case No. 2019 NY Slip Op 06521 [175 AD3d 1331]
Regular Panel Decision
Sep 11, 2019

People v. Snyder

The defendant, Crystal Snyder, appealed an order from the Supreme Court, Queens County, which designated her a level two sex offender under the Sex Offender Registration Act (SORA). Snyder, who had pleaded guilty to federal sex trafficking conspiracy, argued for a downward departure to a level one designation, contending she was a victim herself of the commercial sex trade. The Appellate Division, Second Department, found that the circumstances of her exploitation as a minor and her limited management role, without evidence of recruiting or coercing victims, constituted a mitigating factor not adequately considered by the SORA Guidelines. Consequently, the court reversed the Supreme Court's order, granting Snyder's application for a downward departure and designating her a level one sex offender.

Sex Offender Registration ActSORADownward DepartureRisk LevelSex Trafficking ConspiracyVictim ExploitationAppellate ReviewMitigating FactorsFederal ConvictionPresumptive Risk Category
References
6
Case No. MISSING
Regular Panel Decision

Mordkofsky v. V.C.V. Development Corp.

Plaintiff Norman J. Mordkofsky, a contract-vendee, sustained injuries when a deck at his custom-built home construction site collapsed. He sued defendant V.C.V. Development Corp., alleging negligence and violations of Labor Law §§ 200 and 241. While the Supreme Court dismissed the Labor Law claim, the Appellate Division reinstated it, broadening the protection of these statutes to anyone lawfully frequenting a construction site. However, the higher court reversed the Appellate Division's decision, clarifying that Labor Law §§ 200 and 241 are primarily intended to protect employees and workers, not contract-vendees or the general public. The court concluded that Mordkofsky did not fall within the protected class as he was neither an employee nor hired to work at the site.

Labor Law §§ 200 and 241Construction Site InjuryContract-VendeeEmployee ProtectionStatutory InterpretationScope of Labor LawAppellate ReviewSafe Place to WorkWorkers' RightsPersonal Injury
References
14
Case No. 2025 NYSlipOp 07110
Regular Panel Decision
Dec 18, 2025

People v. R.V.

The Appellate Division, First Department, affirmed an order by the Supreme Court, New York County, which granted the defendant R.V.'s CPL 210.40 motion to dismiss the indictment in furtherance of justice. The court found that the Supreme Court providently exercised its discretion, noting that R.V. purchased a false Covid-19 vaccination card to maintain employment as an essential worker during the pandemic. The decision highlighted that R.V.'s actions caused no specific or societal harm, supporting the dismissal in the interest of justice.

Indictment DismissalInterest of JusticeCPL 210.40COVID-19 Vaccination CardEssential WorkerAppellate ReviewDiscretionary DismissalLack of Harm
References
2
Case No. MISSING
Regular Panel Decision

Wolfgang Doerr v. Daniel Goldsmith / Cheryl Dobinski v. George O. Lockhart

This concurring opinion by Justice Abdus-Salaam addresses two cases, Doerr v Goldsmith and Dobinski v Lockhart, concerning negligence claims against domestic animal owners for injuries caused by their pets. The opinion reaffirms the long-standing "vicious propensities" rule established in Bard v Jahnke, which limits liability solely to strict liability when an owner knew or should have known of an animal's dangerous tendencies. Justice Abdus-Salaam rejects arguments to extend the Hastings v Sauve precedent, which allowed negligence claims for farm animals straying from property, to domestic pets. The opinion also refutes the distinction between an owner's active control and passive failure to restrain, emphasizing that a pet's volitional behavior is the ultimate cause of harm. Consequently, Justice Abdus-Salaam votes to dismiss the negligence claims in both cases and affirms the dismissal of Dobinski's strict liability claim due to insufficient evidence of the owners' prior knowledge of their dogs' propensities.

Animal LawNegligenceStrict LiabilityDomestic AnimalsFarm AnimalsVicious Propensity RuleDuty of CareSummary JudgmentAppellate ReviewCourt of Appeals
References
20
Case No. 2024 NY Slip Op 04584 [232 AD3d 209]
Regular Panel Decision
Sep 25, 2024

Snyder v. AFCO Avports Mgt., LLC

This case concerns a trip-and-fall accident at Stewart International Airport, where plaintiff Kathy Snyder sustained injuries due to an alleged sidewalk defect. Defendants AFCO Avports Management, LLC, and Port Authority of New York & New Jersey moved for summary judgment, asserting the defect was trivial as a matter of law. The Appellate Division, Second Department, addressed key questions regarding the requirement of objective measurements for triviality, the examination of photographic evidence, and the admissibility of human factors expert opinions lacking such measurements. The court held that objective measurements are not a per se requirement, but defendants in this instance failed to meet their prima facie burden. The human factors expert's opinion was deemed conclusory and speculative due to the absence of objective measurements or a reasonably inferable estimate of the defect. Consequently, the lower court's order granting summary judgment to the defendants was reversed, and the motion was denied.

Trip and fallSidewalk defectSummary judgment appealTrivial defect doctrinePhotographic evidenceObjective measurementsHuman factors expert testimonyExpert opinion admissibilityPrima facie burdenAppellate review
References
35
Case No. MISSING
Regular Panel Decision

People v. Johnson

This opinion from the Court of Appeals addresses the critical issue of juror impartiality in criminal trials, specifically concerning challenges for cause when prospective jurors express doubts about their fairness. The Court consolidated three cases: People v. Johnson and People v. Sharper, both robbery cases involving juror bias towards police testimony, and People v. Reyes, a drug sale case where jurors harbored biases related to drug abuse and a defendant's prior convictions. The Court reiterated that when potential jurors reveal a state of mind likely to preclude impartial service, they must provide unequivocal assurance of their ability to set aside any bias and render a verdict based solely on evidence. Concluding that the trial judges in these cases failed to obtain such unequivocal assurances, the Court affirmed the Appellate Division's reversal of convictions in Johnson and Sharper, and reversed the Appellate Division's affirmation of conviction in Reyes, ordering a new trial. This decision underscores the fundamental constitutional right to an impartial jury and clarifies the standard for excusing biased jurors under CPL 270.20.

Jury SelectionVoir DireJuror ImpartialityChallenge for CauseUnequivocal AssurancePolice Testimony BiasDrug Offense BiasPrior Conviction BiasCriminal Procedure LawAppellate Review
References
31
Case No. MISSING
Regular Panel Decision

MATTER OF THEROUX v. Reilly

The New York State Court of Appeals addressed whether eligibility for benefits under General Municipal Law § 207-c requires a 'heightened risk' standard for injuries sustained by municipal employees in law enforcement duties. The court concluded that section 207-c does not mandate such a standard, interpreting 'duties' to encompass the full range of a covered employee's job responsibilities. It clarified that eligibility only necessitates demonstrating a 'direct causal relationship between job duties and the resulting illness or injury.' Consequently, the Court reversed the Appellate Division orders in three consolidated cases (Theroux v Reilly, Wagman v Kapica, and James v County of Yates Sheriff’s Dept.) that had erroneously applied the 'heightened risk' standard, reinstating Supreme Court orders in two and remitting one for further proceedings.

Workers' CompensationGeneral Municipal LawPolice OfficersFirefightersDisability BenefitsStatutory InterpretationAppellate ReviewCausal RelationshipJob DutiesPublic Safety Officers
References
20
Case No. MISSING
Regular Panel Decision

Bartoo v. Buell

This case addresses whether the homeowner exemption of Labor Law § 240 (1) and § 241 (6) applies to structures used for both residential and commercial purposes. The court applies a "site and purpose" test to determine applicability. In Bartoo v Buell, the repair of a barn roof, used for both personal storage and commercial golf cart storage, was deemed primarily residential, thus granting the owner exemption. In Anderson v Flanagan, the addition of a bedroom to a home also operating a daycare center was found to be directly related to residential use, exempting the owner from liability. The Court concluded that owners of one- or two-family dwellings who do not direct or control the work are shielded by the homeowner exemption when the work directly relates to the residential use of the home, even if it also serves a commercial purpose.

Homeowner ExemptionLabor LawDual-Use PropertyResidential UseCommercial UseStrict LiabilitySite and Purpose TestScaffold CollapseRoof RepairBedroom Addition
References
7
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