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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 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

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

Bacon v. County of Westchester

This case involves an appeal by the plaintiffs seeking damages for unlawful imprisonment. The Supreme Court, Westchester County, initially granted summary judgment to the defendants, dismissing the complaint. The appellate court dismissed the appeal from the intermediate order but reversed the judgment, vacated the lower court's order, denied the defendants' motion, and reinstated the complaint. The court found that the defendants' two-hour detention of the plaintiffs during a search warrant execution might not be privileged, thereby raising factual issues regarding their conduct and qualified immunity. Additionally, a prior federal court decision in a civil rights action was deemed not to have collateral estoppel effect on the state law claim of false imprisonment, as the federal court declined to exercise pendent jurisdiction and did not reach a determination on the merits.

Unlawful ImprisonmentFalse ImprisonmentSummary JudgmentAppealSearch WarrantQualified ImmunityCollateral EstoppelCivil RightsState LawPendent Jurisdiction
References
14
Case No. MISSING
Regular Panel Decision

Anderson v. County of Nassau

Pro se plaintiff Joel Anderson filed an amended complaint alleging false arrest, unlawful imprisonment, malicious prosecution, and abuse of process against Nassau County, the City of Long Beach, and Detective Shaun Dowling under 42 U.S.C. § 1983 and New York law. Defendants moved to dismiss all claims under Rule 12(b)(6). The Court granted Nassau County's motion to dismiss false arrest and unlawful imprisonment claims. All Section 1983 malicious prosecution claims and all abuse of process claims against all defendants were dismissed. The remaining claims are false arrest and unlawful imprisonment under Section 1983 and New York law against the City of Long Beach and Detective Dowling, and a New York law claim for malicious prosecution against the City of Long Beach.

Civil RightsFourth AmendmentRule 12(b)(6)False ArrestUnlawful ImprisonmentMalicious ProsecutionAbuse of ProcessMunicipal LiabilityProbable CausePro Se Litigation
References
33
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

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

La Belle v. County of St. Lawrence

This case involves three consolidated actions arising from the temporary removal of two minor children, Randy and Jodi La Belle, by St. Lawrence County Department of Social Services and Massena police officers while their parents, Albert and Joyce La Belle, were on vacation. The parents (Action No. 1) sued for intentional infliction of emotional distress and civil rights violations (42 U.S.C. § 1983). The children (Action Nos. 2 and 3) brought claims for false arrest, false imprisonment, and civil rights violations. This appeal reviews the denial of defendants' motions to dismiss the complaints by the Supreme Court at Special Term. The appellate court modified the order, dismissing the parents' entire action, certain civil rights claims against the County of St. Lawrence and the Village of Massena, and all punitive damages claims against municipalities and for State law claims in Action Nos. 2 and 3. The infant plaintiffs were left with causes of action for false arrest, false imprisonment, and section 1983 claims against the Department of Social Services and individual defendants, with punitive damages claims remaining only against individual defendants for the section 1983 causes of action.

Child ProtectionCivil Rights ViolationFalse ArrestFalse ImprisonmentIntentional Infliction of Emotional DistressGovernment ImmunityPunitive DamagesMunicipal LiabilityRespondeat SuperiorAppellate Review
References
16
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
Case No. MISSING
Regular Panel Decision

Petrenko v. United States

Plaintiff John Petrenko filed a 42 U.S.C. § 1983 action against the United States, alleging civil rights violations including negligent beating, false arrest, and false imprisonment stemming from a 1988 incident with United States Park Police officers. Petrenko sought $10 million in damages. The Government moved for summary judgment, which the court granted. The court ruled that the United States is immune from § 1983 suits and that prior state court findings of probable cause precluded the false arrest and imprisonment claims. Petrenko's negligent beating claim was dismissed due to insufficient evidence, and his state claim for vehicle impoundment costs was also dismissed for lack of subject matter jurisdiction, as adequate state remedies exist.

42 U.S.C. § 1983Civil Rights ViolationFalse ArrestFalse ImprisonmentNegligent BeatingSummary JudgmentSovereign ImmunityCollateral EstoppelProbable CauseFederal Question Jurisdiction
References
18
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