essential elements claim (New York) · Go Syfert
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essential elements claim in New York

42 New York opinions name it 3 courts 1894–2025 9 in the last five years

The cases below were cited by New York courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (27)

CaseFollowedCited
North v. Board of Examinersgreen
ny · 2007 · cited in 7 New York opinions naming this issue, 2014–2024
2 sentences

2024Pursuant to the essential elements test, a court must "compare the elements of the foreign [*2]offense with the analogous New York offense to identify points of overlap" and, "where the offenses overlap but the foreign offense also criminalizes conduct not covered under the New York offense, the [court] must review the conduct underlying the foreign conviction to determine if that conduct is, in fact, within the scope of the New York offense" ( Matter of North v Board of Examiners of Sex Offenders of State of N.Y. , 8 NY3d 745, 753 [2007]; see People v Perez , 35 NY3d at 93).

2024Thus, the conduct of which defendant was convicted under the Kansas statute, if committed in New York, would have amounted to a sexually violent offense under New York law ( see North , 8 NY3d at 753 ), regardless of whether we begin our analysis with the essential elements test or the unchallenged conduct described in the case summary.

57
People v. Cremeansgreen
nyappdiv · 2021 · cited in 3 New York opinions naming this issue, 2021–2024
2 sentences

2024People v Hicks , 203 AD3d 1679, 1679-1680 [4th Dept 2022], lv denied 38 NY3d 910 [2022]; People v Smith , 199 AD3d 1188, 1191-1192 [3d Dept 2021]; People v Cremeans , 194 AD3d 1369, 1370-1371 [4th Dept 2021], lv denied 37 NY3d 910 [2021]; People v Bean , 190 AD3d 622 , 622-623 [1st Dept 2021], lv denied 36 NY3d 913 [2021]; People v Smith , 175 AD3d 572 , 573 [2d Dept 2019]).

2023In circumstances where the offenses overlap but the foreign offense also criminalizes conduct not covered under the New York offense, the Board must review the conduct underlying the foreign conviction to determine if that conduct is, in fact, within the scope of the New York offense" ( Matter of North v Board of Examiners of Sex Offenders of State of N.Y. , 8 NY3d 745, 753 [2007]; see People v Perez , 35 NY3d 85 , 93 [2020], rearg denied 35 NY3d 986 [2020]; People v Cremeans , 194 AD3d 1369, 1370 [4th Dept 2021], lv denied 37 NY3d 910 [2021]).

33
Alvarez v. Prospect Hospitalgreen
ny · 1986 · cited in 4 New York opinions naming this issue, 1998–2010
2 sentences

2010General allegations of medical malpractice, merely conclusory in nature and unsupported by competent evidence tending to establish the essential elements of the claim, are insufficient to defeat a defendant physician’s entitlement to summary judgment (see Alvarez v Prospect Hosp., 68 NY2d at 325 ).

2007In opposition to the motions, plaintiff submitted the affidavit of an expert that contained only “ ‘[g]eneral allegations of medical malpractice, [which were] merely conclusoiy in nature and unsupported by competent evidence tending to establish the essential elements of the claim’ ” (Mendez, 295 AD2d at 488 ; see Alvarez v Prospect Hosp., 68 NY2d 320, 325 [1986]).

24
Misicki v. Caradonnagreen
ny · 2009 · cited in 2 New York opinions naming this issue, 2024–2025
2 sentences

2025We decline to consider that alternative basis for affirmance, sua sponte, for the first time on appeal ( see generally Misicki v Caradonna , 12 NY3d 511, 519 [2009]).

2024Lindley, J.P., Keane, and Hannah, JJ., concur; Curran, J., concurs in the following memorandum: I respectfully concur with the majority insofar as it concludes that the matter must be remitted to County Court for consideration of whether defendant is a sexually violent offender under the essential elements test found in the first disjunctive clause of Correction Law § 168-a (3) (b) ( see generally CPLR 5522 [a]; People v Weber , 40 NY3d 206 , 211-212 [2023])—an issue the majority properly declines to consider as an alternative basis for affirmance, sua sponte, for the first time on appeal ( se

22
Steele v. Watsongreen
nyappdiv · 2007 · cited in 2 New York opinions naming this issue, 2012–2012
2 sentences

2012On the contrary, the record demonstrated that plaintiffs decedent had viable causes of action for breach of the warranty of habitability and nuisance against defendants in the underlying action (see 61 W. 62 Owners Corp. v CGM EMP LLC, 77 AD3d 330 [1st Dept 2010], affd in part, mod in part 16 NY3d 822 [2011]; Misra v Yedid, 37 AD3d 284, 285 [1st Dept 2007]).

2012On the contrary, the record demonstrated that plaintiffs decedent had viable causes of action for breach of the warranty of habitability and nuisance against defendants in the underlying action (see 61 W. 62 Owners Corp. v CGM EMP LLC, 77 AD3d 330 [1st Dept 2010], affd in part, mod in part 16 NY3d 822 [2011]; Misra v Yedid, 37 AD3d 284, 285 [1st Dept 2007]).

22
People v. Diazgreen
ny · 2018 · cited in 2 New York opinions naming this issue, 2022–2025
2 sentences

2025"The Adam Walsh Child Protection and Safety Act of 2006, which superseded the JWA, continues to place compliance requirements on states subject to guidelines issued by the Attorney General" ( People v Diaz , 32 NY3d at 541; see 34 USC §§ 20912, 20927).

2025"After several amendments to the JWA, including Megan's Law as well as the Pam Lychner Act, Congress added a reciprocity requirement in 1997" ( People v Diaz , 32 NY3d at 541 [footnotes omitted]).

12
People v. Smithgreen
nyappdiv · 2021 · cited in 1 New York opinions naming this issue, 2024–2024
2 sentences

2024People v Hicks , 203 AD3d 1679, 1679-1680 [4th Dept 2022], lv denied 38 NY3d 910 [2022]; People v Smith , 199 AD3d 1188, 1191-1192 [3d Dept 2021]; People v Cremeans , 194 AD3d 1369, 1370-1371 [4th Dept 2021], lv denied 37 NY3d 910 [2021]; People v Bean , 190 AD3d 622 , 622-623 [1st Dept 2021], lv denied 36 NY3d 913 [2021]; People v Smith , 175 AD3d 572 , 573 [2d Dept 2019]).

2024People v Smith , 199 AD3d at 1191 ).

11
People v. Knoxgreen
ny · 2009 · cited in 1 New York opinions naming this issue, 2024–2024
1 sentence

2024In sum, defendant failed to establish that he was not a sexually violent offender under New York law and, as such, there can be no violation of his "constitutionally-protected liberty interest, applicable in a substantive due process context, in not being required to register under an incorrect [designation]" ( Knox , 12 NY3d at 66 [emphasis added]).

11
People v. Hicksgreen
nyappdiv · 2022 · cited in 1 New York opinions naming this issue, 2024–2024
1 sentence

2024People v Hicks , 203 AD3d 1679, 1679-1680 [4th Dept 2022], lv denied 38 NY3d 910 [2022]; People v Smith , 199 AD3d 1188, 1191-1192 [3d Dept 2021]; People v Cremeans , 194 AD3d 1369, 1370-1371 [4th Dept 2021], lv denied 37 NY3d 910 [2021]; People v Bean , 190 AD3d 622 , 622-623 [1st Dept 2021], lv denied 36 NY3d 913 [2021]; People v Smith , 175 AD3d 572 , 573 [2d Dept 2019]).

11
People v. Bullockgreen
nyappdiv · 2014 · cited in 1 New York opinions naming this issue, 2021–2021
1 sentence

2021In circumstances where the offenses overlap but the foreign offense also criminalizes conduct not covered under the New York offense, the Board must review the conduct underlying the foreign conviction to determine if that conduct is, in fact, within the scope of the New York offense" ( Matter of North v Board of Examiners of Sex Offenders of State of N.Y. , 8 NY3d 745, 753 [2007]; see People v Perez , 35 NY3d 85 , 92-94 [2020], rearg denied 35 NY3d 986 [2020]; People v Bullock , 125 AD3d 1, 3 [1st Dept 2014], lv denied 24 NY3d 915 [2015]).

11
State of New York v. Rashidgreen
ny · 2010 · cited in 1 New York opinions naming this issue, 2011–2011
1 sentence

2011Respondent was incarcerated on a sex offense approaching the end of his incarceration, and a case could be made that he “requir[ed] civil manage ment.” (Rashid, 16 NY3d at 16 [Legislature intended article 10 to deal with civil management of sex offenders who are completing their prison terms].) However, the petition cannot survive merely because it sufficiently stated a claim at the time of filing.

11
Braddock v. Braddockgreen
nyappdiv · 2009 · cited in 1 New York opinions naming this issue, 2010–2010
1 sentence

2010The essential elements of a claim for fraudulent inducement are “the misrepresentation of a material fact, which was known by the defendant to be false and intended to be relied on when made, and that there was justifiable reliance and resulting injury.” (Braddock v Braddock, 60 AD3d 84, 86 [1st Dept 2009].) “Although the issue of justifiable reliance is generally a question of fact that is not amenable to summary resolution ... we have held that ‘[a]s a matter of law, a sophisticated plaintiff cannot establish that it entered into an arm’s length transaction in justifiable reliance on alleged

11
Ventur Group, LLC v. Finnertygreen
nyappdiv · 2009 · cited in 1 New York opinions naming this issue, 2010–2010
1 sentence

2010The essential elements of a claim for fraudulent inducement are “the misrepresentation of a material fact, which was known by the defendant to be false and intended to be relied on when made, and that there was justifiable reliance and resulting injury.” (Braddock v Braddock, 60 AD3d 84, 86 [1st Dept 2009].) “Although the issue of justifiable reliance is generally a question of fact that is not amenable to summary resolution ... we have held that ‘[a]s a matter of law, a sophisticated plaintiff cannot establish that it entered into an arm’s length transaction in justifiable reliance on alleged

11
NY Univ. v. CONT'L INS COgreen
ny · 1995 · cited in 1 New York opinions naming this issue, 2009–2009
1 sentence

2009Co., 87 NY2d 308, 318 [1995]; Channel Master Corp. v Aluminium Ltd.

11
Channel Master Corp. v. Aluminium Limited Sales, Inc.green
ny · 1958 · cited in 1 New York opinions naming this issue, 2007–2007
1 sentence

2007Sales, 4 NY2d 403, 406-407 [1958]).

11
Blume v. A & R Fuels, Inc.green
nyappdiv · 2006 · cited in 1 New York opinions naming this issue, 2007–2007
1 sentence

2007Accordingly, the Supreme Court correctly found that the plaintiffs allegations failed to set forth the essential elements of a claim for tortious interference with contractual relations (id.; see Blume v A & R Fuels, Inc., 32 AD3d 811, 812 [2006]; Conciatori v Longworth, 259 AD2d 459, 460 [1999]).

11
Conciatori v. Longworthgreen
nyappdiv · 1999 · cited in 1 New York opinions naming this issue, 2007–2007
1 sentence

2007Accordingly, the Supreme Court correctly found that the plaintiffs allegations failed to set forth the essential elements of a claim for tortious interference with contractual relations (id.; see Blume v A & R Fuels, Inc., 32 AD3d 811, 812 [2006]; Conciatori v Longworth, 259 AD2d 459, 460 [1999]).

11
McGrath v. Toys \R\" USred
· 2004 · cited in 1 New York opinions naming this issue, 2006–2006
11
Patrick C. Jackan, United States of America, Intervenor v. New York State Department of Laborgreen
ca2 · 2000 · cited in 1 New York opinions naming this issue, 2006–2006
11
United Commodities-Greece v. Fidelity International Bankgreen
ny · 1985 · cited in 1 New York opinions naming this issue, 2004–2004
11
Karlsons v. Guerinotgreen
nyappdiv · 1977 · cited in 1 New York opinions naming this issue, 2003–2003
11
Porter v. Uniroyal Goodrich Tire Co.green
nyappdiv · 1996 · cited in 1 New York opinions naming this issue, 2003–2003
11
Schel v. Rothgreen
nyappdiv · 1997 · cited in 1 New York opinions naming this issue, 2003–2003
11
Restrepo v. Stategreen
nyclaimsct · 1989 · cited in 1 New York opinions naming this issue, 1998–1998
11
Restrepo v. Stategreen
nyappdiv · 1992 · cited in 1 New York opinions naming this issue, 1998–1998
11
Otis Elevator Co. v. Stategreen
nyappdiv · 1976 · cited in 1 New York opinions naming this issue, 1979–1979
11
Young v. Stategreen
nyclaimsct · 1978 · cited in 1 New York opinions naming this issue, 1979–1979
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in New York. Read the followed side critically anyway.

Also cited on this issue (32)

CaseCitedYears
Kramer v. Rosenthal green
nyappdiv · 1996
2 sentences

2003“General allegations of medical malpractice, merely conclusory in nature and unsupported by competent evidence tending to establish the essential elements of the claim, are insufficient to defeat a defendant physician’s entitlement to summary judgment” (Kramer v Rosenthal, 224 AD2d 392 [1996]).

1998The plaintiffs’ conclusory allegations of malpractice, unsupported by competent evidence tending to establish the essential elements of their claim, were insufficient to defeat the defendant’s motion (cf, Alvarez v Prospect Hosp., 68 NY2d 320, 324-325 ; Kramer v Rosenthal, 224 AD2d 392 ; see generally, Annotation, Veterinary Malpractice, 71 ALR4th 811, 821-822; compare, Matter of Restrepo v State of New York, 146 Misc 2d 349 , affd 179 AD2d 804 ).

41996–2003
Citibank, N. A. v. Saratoga Condominium green
nyappdiv · 1994
2 sentences

1998The requisite elements of proof in a medical malpractice action are a deviation or departure from accepted practice and evidence that such departure was a proximate cause of injury or damage (see, Bloom v City of New York, 202 AD2d 465 )” (Kramer v Rosenthal, 224 AD2d 392 ).

1996The requisite elements of proof in a medical malpractice action are a deviation or departure from accepted practice and evidence that such departure was a proximate cause of injury or damage (see, Bloom v City of New York, 202 AD2d 465 ).

31996–1998
Velie v. Ellis Law, P.C. green
nyappdiv · 2008
2 sentences

2015Where the motion is premised on an argument that the plaintiff could not succeed on her claim below, it is the defendant’s burden to demonstrate that the plaintiff would be unable to prove one of the essential elements of her claim (see *596 Velie v Ellis Law, P.C., 48 AD3d 674 [2d Dept 2008]).

2011Where the motion is premised on an argument that the plaintiff could not succeed on her claim below, it is defendant’s burden to demonstrate that the plaintiff would be unable to prove one of the essential elements of her claim (see Velie v Ellis Law, P.C., 48 AD3d 674 [2008]).

22011–2015
61 West 62 Owners Corp. v. CGM EMP LLC green
nyappdiv · 2010
2 sentences

2012On the contrary, the record demonstrated that plaintiffs decedent had viable causes of action for breach of the warranty of habitability and nuisance against defendants in the underlying action (see 61 W. 62 Owners Corp. v CGM EMP LLC, 77 AD3d 330 [1st Dept 2010], affd in part, mod in part 16 NY3d 822 [2011]; Misra v Yedid, 37 AD3d 284, 285 [1st Dept 2007]).

2012On the contrary, the record demonstrated that plaintiffs decedent had viable causes of action for breach of the warranty of habitability and nuisance against defendants in the underlying action (see 61 W. 62 Owners Corp. v CGM EMP LLC, 77 AD3d 330 [1st Dept 2010], affd in part, mod in part 16 NY3d 822 [2011]; Misra v Yedid, 37 AD3d 284, 285 [1st Dept 2007]).

22012–2012
People v. Thanh Do green
nyappdiv · 2011
2 sentences

2012Defendants failed to sustain their burden on summary judgment of demonstrating that plaintiff would be unable to prove one of the essential elements of his claim (see Sabalza v Salgado, 85 AD3d 436 [1st Dept 2011]).

2012Defendants failed to sustain their burden on summary judgment of demonstrating that plaintiff would be unable to prove one of the essential elements of his claim (see Sabalza v Salgado, 85 AD3d 436 [1st Dept 2011]).

22012–2012
61 West 62 Owners Corp. v. CGM EMP LLC green
ny · 2011
2 sentences

2012On the contrary, the record demonstrated that plaintiffs decedent had viable causes of action for breach of the warranty of habitability and nuisance against defendants in the underlying action (see 61 W. 62 Owners Corp. v CGM EMP LLC, 77 AD3d 330 [1st Dept 2010], affd in part, mod in part 16 NY3d 822 [2011]; Misra v Yedid, 37 AD3d 284, 285 [1st Dept 2007]).

2012On the contrary, the record demonstrated that plaintiffs decedent had viable causes of action for breach of the warranty of habitability and nuisance against defendants in the underlying action (see 61 W. 62 Owners Corp. v CGM EMP LLC, 77 AD3d 330 [1st Dept 2010], affd in part, mod in part 16 NY3d 822 [2011]; Misra v Yedid, 37 AD3d 284, 285 [1st Dept 2007]).

22012–2012
Toledo v. Ordway green
nyappdiv · 1994
2 sentences

1998General allegations of medical malpractice, merely conclusory in nature and unsupported by competent evidence tending to establish the essential elements of the claim, are insufficient to defeat a defendant physician’s entitlement to summary judgment (see, Alvarez v Prospect Hosp., supra; Toledo v Ordway, supra).

1996General allegations of medical malpractice, merely conclusory in nature and unsupported by competent evidence tending to establish the essential elements of the claim, are insufficient to defeat a defendant physician’s entitlement to summary judgment (see, Alvarez v Prosepct Hosp., supra; Toledo v Ordway, supra).

21996–1998
People v. Major green
nyappdiv · 1986
2 sentences

1991The defendant’s failure to retreat and the number of stab wounds sustained by the decedent negate the essential elements of the defense (see, People v Turner, 165 AD2d 798 ; People v Major, 116 AD2d 594 ).

1990(People v Major, 116 AD2d 594, 595 , lv denied 67 NY2d 886 .) Concur — Kupferman, J.

21990–1991
People v. Pidel green
nyappdiv · 2021
1 sentence

2021In circumstances where the offenses overlap but the foreign offense also criminalizes conduct not covered under the New York offense, the Board must review the conduct underlying the foreign conviction to determine if that conduct is, in fact, within the scope of the New York offense" ( Matter of North v Board of Examiners of Sex Offenders of State of N.Y. , 8 NY3d 745, 753 [2007]; see People v Perez , 35 NY3d at 92-94; People v Pidel , 195 AD3d at 1323-1324 ; People v Cremeans , 194 AD3d 1369, 1370 [2021], lv denied 37 NY3d 910 [2021]).

12021–2021
Gill v. Maul green
nyappdiv · 2009
1 sentence

2012Appeal Bd.] v New York State Div. of Human Rights, 71 AD3d at 1236-1238 ), and thus failed to establish the essential elements of her claim (see Gill v Maul, 61 AD3d at 1160-1161 ).

12012–2012
New York State Department of Labor v. New York State Division of Human Rights green
nyappdiv · 2010
1 sentence

2012Appeal Bd.] v New York State Div. of Human Rights, 71 AD3d at 1236-1238 ), and thus failed to establish the essential elements of her claim (see Gill v Maul, 61 AD3d at 1160-1161 ).

12012–2012
McGregor v. Frank Manzo green
nyappdiv · 2002
1 sentence

2007In opposition to the motions, plaintiff submitted the affidavit of an expert that contained only “ ‘[g]eneral allegations of medical malpractice, [which were] merely conclusoiy in nature and unsupported by competent evidence tending to establish the essential elements of the claim’ ” (Mendez, 295 AD2d at 488 ; see Alvarez v Prospect Hosp., 68 NY2d 320, 325 [1986]).

12007–2007
Barclay Arms, Inc. v. Barclay Arms Associates green
ny · 1989
1 sentence

2007The essential elements of a claim of fraud are misrepresentation of a material fact, falsity, scienter and deception (Barclay Arms, 74 NY2d at 646-647 ; Channel Master Corp. v Aluminium Ltd.

12007–2007
Belzel v. United States green
scotus · 2000
12006–2006
Claim of Mlodozeniec v. Worthington Corp. neutral
nyappdiv · 1959
12001–2001
Martin v. City of Albany green
ny · 1977
11998–1998
Broughton v. State green
ny · 1975
11998–1998
Colon v. City of New York green
ny · 1983
11998–1998
People v. Blake green
nyappdiv · 1988
11993–1993
People v. Duncan neutral
ny · 1963
11993–1993
People v. Paperno green
ny · 1981
11993–1993
People v. Woods neutral
nyappdiv · 1990
11991–1991
Burba v. Rochester Gas & Electric Corp green
nyappdiv · 1982
11989–1989
Israel v. Wood Dolson Co. green
ny · 1956
11989–1989
People v. Charles neutral
nyappdiv · 1983
11986–1986
People v. Alston green
nyappdiv · 1984
11986–1986
Groesbeck v. . Morgan green
ny · 1912
11986–1986
Calhoun v. . Millard green
ny · 1890
11986–1986
In re the Estate of Barabash green
ny · 1972
11986–1986
Harvey Chalmers & Son, Inc. v. State green
ny · 1947
11979–1979
Wagner v. Armsby neutral
nyappdiv · 1942
11945–1945
Dickerson v. . Wason neutral
ny · 1872
11894–1894

Statutes the citing opinions construe

NY § N.Y. Correction Law § 168 (9) NY § N.Y. Penal Law § 130.65 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

OH 192 (1978–2025) TX 143 (1937–2024) TN 107 (1976–2024) WA 101 (1961–2026) ID 70 (1955–2026) LA 53 (1938–2022) GA 50 (1935–2024) NC 48 (1978–2025) WY 44 (1979–2020) NY 42 (1894–2025) CA 42 (1920–2026) NM 31 (1971–2025) IL 31 (1971–2026) FL 30 (1942–2026) CT 28 (1963–2019) MO 26 (1957–2016) IN 25 (1972–2026) MS 24 (1995–2025) MA 23 (1991–2025) HI 20 (1995–2026) OR 19 (1984–2025) AL 18 (1923–2024) PA 17 (1926–2024) OK 16 (1911–2021) WV 14 (1987–2025) KY 13 (1949–2026) KS 12 (1953–2021) VA 12 (1988–2025) IA 11 (1935–2026) ME 10 (2011–2023) MI 10 (2014–2026) MD 9 (1923–2010) VT 8 (2003–2026) NJ 8 (1979–2025) ND 6 (1978–1996) DC 6 (1979–2003) AZ 6 (1936–1983) MN 5 (1972–2016) UT 5 (1994–2023) RI 5 (1987–2006) SC 4 (1932–2000) MT 4 (1989–2022) CO 3 (1988–2025) SD 3 (1992–2002) AK 3 (1991–2014) AR 3 (1998–2010)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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