overriding principle (New York) · Go Syfert
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overriding principle in New York

36 New York opinions name it 7 courts 1956–2024 3 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 (14)

CaseFollowedCited
Society of Plastics Industry, Inc. v. County of Suffolkgreen
ny · 1991 · cited in 3 New York opinions naming this issue, 2016–2016
2 sentences

2016To that end, the overriding principle of SEQRA is the “maintenance of a quality environment for the people of this state” (ECL 8-0103 [1]), and “every citizen ‘has a responsibility to contribute to the preservation and enhancement of the quality of the environment’ ” (Society of Plastics Indus., 77 NY2d at 777, quoting ECL 8-0103 [2]).

2016To that end, the overriding principle of SEQRA is the “maintenance of a quality environment for the people of this state” (ECL 8-0103 [1]), and “every citizen ‘has a responsibility to contribute to the preservation and enhancement of the quality of the environment’ ” (Society of Plastics Indus., 77 NY2d at 777, quoting ECL 8-0103 [2]).

33
Sandstrom v. Montanagreen
scotus · 1979 · cited in 3 New York opinions naming this issue, 1983–2005
2 sentences

2005Such a result “conflicts with the defendant’s overriding presumption of innocence as to every element of the crime, and invades the jury’s fact-finding function” (People v Williams, 95 AD2d 866 [1983]; see Sandstrom v Montana, supra; People v Williams, supra at 136).

1983A mandatory presumption as to an element of a crime is unconstitutional because it conflicts with the defendant’s overriding presumption of innocence as to every element of the crime, and invades the jury’s fact-finding function (Sandstrom v Montana, 442 US 510;People v Gray, supra).

13
Reed, Roberts Associates, Inc. v. Straumangreen
ny · 1976 · cited in 2 New York opinions naming this issue, 1987–2005
2 sentences

2005Under New York law, “negative covenants restricting competition are enforceable only to the extent that they satisfy the overriding requirement of reasonableness.” (Reed, Roberts Assoc. v Strauman, 40 NY2d 303, 307 [1976].) “An employee agreement not to compete will be enforced only if ‘it is reasonable in time and area, necessary to protect the employer’s legitimate interests, not harmful to the general public and not unreasonably burdensome to the employee.’ ” (Scott, Stackrow & Co., C.P.A.'s, P.C. v Skavina, 9 AD3d 805, 806 [3d Dept 2004].) This general limitation of reasonableness “applies

1987The restrictive covenant between the plaintiff and the Franzeses falls within the general rule that "covenants restricting competition are enforceable only to the extent that they satisfy the overriding requirement of reasonableness” (Reed, Roberts Assocs. v Strauman, 40 NY2d 303, 307 , rearg denied 40 NY2d 918 ).

12
The Matter of Sierra Club v. Village of Painted Postgreen
ny · 2015 · cited in 1 New York opinions naming this issue, 2016–2016
1 sentence

2016Those seeking to raise SEQRA challenges must establish both “an environmental injury that is in some way different from that of the public at large, and . . . that the alleged injury falls within the zone of interests sought to be protected or promoted by SEQRA” (Matter of Tuxedo Land Trust, Inc. v Town Bd. of Town of Tuxedo, 112 AD3d 726 , 727-728 [emphasis added]; see Matter of Sierra Club v Village of Painted Post, 26 NY3d 301 , ___; Matter of Save the Pine Bush, Inc. v Common Council of City of Albany, 13 NY3d 297, 308-309 ; Matter of Barrett v Dutchess County Legislature, 38 AD3d 651, 653

11
Rumpff v. Schorppgreen
nyappdiv · 2015 · cited in 1 New York opinions naming this issue, 2016–2016
1 sentence

2016The best interests of the children may also be considered in a custody dispute between a parent and nonparent, but only if the nonparent demonstrates, insofar as is relevant here, extraordinary circumstances to overcome a parent’s overriding claim of custody to his or her child (see Matter of Rumpff v Schorpp, 133 AD3d 1109, 1110 [2015]).

11
Darweger v. Staatsgreen
ny · 1935 · cited in 1 New York opinions naming this issue, 2006–2006
2 sentences

2006The principle in effect in this case, as has been true in other cases, is that “legislative intent is the great and controlling principle” (see Matter of Theroux v Reilly, 1 NY3d 232, 244 [2003]; Matter of Sutka v Conners, 73 NY2d 395, 403 [1989]; Stoats, 267 NY 290, 306 [1935], supra).

2006The principle in effect in this case, as has been true in other cases, is that "legislative intent is the great and controlling principle" ( see Matter of Theroux v Reilly, 1 NY3d 232, 244 [2003]; Matter of Sutka v Conners, 73 NY2d 395, 403 [1989]; Staats, 267 NY 290, 306 [1935], supra ).

11
MATTER OF THEROUX v. Reillygreen
ny · 2003 · cited in 1 New York opinions naming this issue, 2006–2006
2 sentences

2006The principle in effect in this case, as has been true in other cases, is that “legislative intent is the great and controlling principle” (see Matter of Theroux v Reilly, 1 NY3d 232, 244 [2003]; Matter of Sutka v Conners, 73 NY2d 395, 403 [1989]; Stoats, 267 NY 290, 306 [1935], supra).

2006The principle in effect in this case, as has been true in other cases, is that "legislative intent is the great and controlling principle" ( see Matter of Theroux v Reilly, 1 NY3d 232, 244 [2003]; Matter of Sutka v Conners, 73 NY2d 395, 403 [1989]; Staats, 267 NY 290, 306 [1935], supra ).

11
Sutka v. Connersgreen
ny · 1989 · cited in 1 New York opinions naming this issue, 2006–2006
2 sentences

2006The principle in effect in this case, as has been true in other cases, is that “legislative intent is the great and controlling principle” (see Matter of Theroux v Reilly, 1 NY3d 232, 244 [2003]; Matter of Sutka v Conners, 73 NY2d 395, 403 [1989]; Stoats, 267 NY 290, 306 [1935], supra).

2006The principle in effect in this case, as has been true in other cases, is that "legislative intent is the great and controlling principle" ( see Matter of Theroux v Reilly, 1 NY3d 232, 244 [2003]; Matter of Sutka v Conners, 73 NY2d 395, 403 [1989]; Staats, 267 NY 290, 306 [1935], supra ).

11
BDO Seidman v. Hirshberggreen
ny · 1999 · cited in 1 New York opinions naming this issue, 2005–2005
2 sentences

2005Under New York law, “negative covenants restricting competition are enforceable only to the extent that they satisfy the overriding requirement of reasonableness.” (Reed, Roberts Assoc. v Strauman, 40 NY2d 303, 307 [1976].) “An employee agreement not to compete will be enforced only if ‘it is reasonable in time and area, necessary to protect the employer’s legitimate interests, not harmful to the general public and not unreasonably burdensome to the employee.’ ” (Scott, Stackrow & Co., C.P.A.'s, P.C. v Skavina, 9 AD3d 805, 806 [3d Dept 2004].) This general limitation of reasonableness “applies

2005Although the rule of reasonableness in cases involving professionals “giv[e] greater weight to the interests of the employer in restricting competition within a confined geographical area” because “professionals are deemed to provide ‘unique or extraordinary’ services” (id., quoting Reed, Roberts Assoc., 40 NY2d at 308 ), the Court of Appeals nevertheless requires strict scrutiny of “the particular facts and circumstances giving context to the agreement” in the learned profession cases. ( 93 NY2d at 390 ; see Gelder Med.

11
Scott, Stackrow & Co., C.P.A.'S, P.C. v. Skavinagreen
nyappdiv · 2004 · cited in 1 New York opinions naming this issue, 2005–2005
1 sentence

2005Under New York law, “negative covenants restricting competition are enforceable only to the extent that they satisfy the overriding requirement of reasonableness.” (Reed, Roberts Assoc. v Strauman, 40 NY2d 303, 307 [1976].) “An employee agreement not to compete will be enforced only if ‘it is reasonable in time and area, necessary to protect the employer’s legitimate interests, not harmful to the general public and not unreasonably burdensome to the employee.’ ” (Scott, Stackrow & Co., C.P.A.'s, P.C. v Skavina, 9 AD3d 805, 806 [3d Dept 2004].) This general limitation of reasonableness “applies

11
Purchasing Associates, Inc. v. Weitzgreen
ny · 1963 · cited in 1 New York opinions naming this issue, 2005–2005
1 sentence

2005Under New York law, “negative covenants restricting competition are enforceable only to the extent that they satisfy the overriding requirement of reasonableness.” (Reed, Roberts Assoc. v Strauman, 40 NY2d 303, 307 [1976].) “An employee agreement not to compete will be enforced only if ‘it is reasonable in time and area, necessary to protect the employer’s legitimate interests, not harmful to the general public and not unreasonably burdensome to the employee.’ ” (Scott, Stackrow & Co., C.P.A.'s, P.C. v Skavina, 9 AD3d 805, 806 [3d Dept 2004].) This general limitation of reasonableness “applies

11
P. J. Panzeca, Inc. v. Aliziogreen
nyappdiv · 1976 · cited in 1 New York opinions naming this issue, 2000–2000
1 sentence

2000We begin by noting that when originally enacted in 1957, the Legislature intended that the exemption from the “rules of the road” contained in Vehicle and Traffic Law § 1103 (b) “refer [ ] to those who build highways, repair or maintain them, paint the pavement markings, remove the snow, sand the pavement and do similar work” (1954 NY Legis Doc No. 36, at 35 [emphasis supplied]; see, Petosa v City of New York, 52 AD2d 919, 920).

11
Grumman Aircraft Engineering Corp. v. Board of Assessorsgreen
ny · 1957 · cited in 1 New York opinions naming this issue, 1988–1988
11
Eaton v. New York City Conciliation & Appeals Boardgreen
ny · 1982 · cited in 1 New York opinions naming this issue, 1986–1986
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 (36)

CaseCitedYears
People v. De Bour green
ny · 1976
2 sentences

2024"The overriding requirement of reasonableness in any event, must prevail" ( id. ).

1979The Court of Appeals in De Bour was clearly mindful of the necessity to avoid placing "unrealistic restrictions” on the authority of the police to approach citizens, and declared "reasonableness” to be "the overriding requirement.” Obviously, if the police may justifiably approach a citizen and address questions to that citizen based not on mere caprice, but because there is "some objective credible reason” to do so, albeit that objective reason is not necessarily indicative of criminality (People v De Bour, supra), the nature of those questions may be directed toward and based upon that very

21979–2024
Long Island University v. J. Baranello & Sons green
nyappdiv · 1986
2 sentences

2022The overriding principle espoused by Rothman is that "[d]efendants ha[ve] a constitutional right to notice of the charges on which they were to be tried' ( 117 AD2d at 535 ).

2022The overriding principle espoused by Rothman is that "[d]efendants ha[ve] a constitutional right to notice of the charges on which they were to be tried' ( 117 AD2d at 535 ).

22022–2022
Fink v. Lefkowitz green
ny · 1979
2 sentences

1989In dealing with requests for disclosure pursuant to FOIL, the overriding principle is that the public is vested with an inherent right to know (Matter of Fink v Lefkowitz, 47 NY2d 567, 571 ).

1980In dealing with requests for disclosure pursuant to the Freedom of Information Law, the overriding principle is that "the public is vested with an inherent right to know” (Matter of Fink v Lefkowitz, 47 NY2d 567, 571 ).

21980–1989
Caniglia v. Strom green
scotus · 2021
1 sentence

2024However, in Caniglia v Strom , the Supreme Court strongly signaled its disapproval of intrusions justified on so-called community caretaking grounds and suggested that Cady did not mark the introduction of a separate community-caretaking doctrine ( 593 US 194 [2021]).

12024–2024
Tuxedo Land Trust, Inc. v. Town Board of Town of Tuxedo green
nyappdiv · 2013
1 sentence

2016Those seeking to raise SEQRA challenges must establish both “an environmental injury that is in some way different from that of the public at large, and . . . that the alleged injury falls within the zone of interests sought to be protected or promoted by SEQRA” (Matter of Tuxedo Land Trust, Inc. v Town Bd. of Town of Tuxedo, 112 AD3d 726 , 727-728 [emphasis added]; see Matter of Sierra Club v Village of Painted Post, 26 NY3d 301 , ___; Matter of Save the Pine Bush, Inc. v Common Council of City of Albany, 13 NY3d 297, 308-309 ; Matter of Barrett v Dutchess County Legislature, 38 AD3d 651, 653

12016–2016
Barrett v. Dutchess County Legislature green
nyappdiv · 2007
1 sentence

2016Those seeking to raise SEQRA challenges must establish both “an environmental injury that is in some way different from that of the public at large, and . . . that the alleged injury falls within the zone of interests sought to be protected or promoted by SEQRA” (Matter of Tuxedo Land Trust, Inc. v Town Bd. of Town of Tuxedo, 112 AD3d 726 , 727-728 [emphasis added]; see Matter of Sierra Club v Village of Painted Post, 26 NY3d 301 , ___; Matter of Save the Pine Bush, Inc. v Common Council of City of Albany, 13 NY3d 297, 308-309 ; Matter of Barrett v Dutchess County Legislature, 38 AD3d 651, 653

12016–2016
Save the Pine Bush, Inc. v. Common Council green
ny · 2009
1 sentence

2016Those seeking to raise SEQRA challenges must establish both “an environmental injury that is in some way different from that of the public at large, and . . . that the alleged injury falls within the zone of interests sought to be protected or promoted by SEQRA” (Matter of Tuxedo Land Trust, Inc. v Town Bd. of Town of Tuxedo, 112 AD3d 726 , 727-728 [emphasis added]; see Matter of Sierra Club v Village of Painted Post, 26 NY3d 301 , ___; Matter of Save the Pine Bush, Inc. v Common Council of City of Albany, 13 NY3d 297, 308-309 ; Matter of Barrett v Dutchess County Legislature, 38 AD3d 651, 653

12016–2016
People v. Sandoval green
ny · 1974
2 sentences

2013As articulated in the well-known Court of Appeals decision in People v Sandoval ( 34 NY2d 371 [1974]), the overriding standard governing the “sound discretion” of the trial judge over the nature and extent of cross-examination (see id. at 374 ) is “whether the prejudicial effect of impeachment testimony far outweighs the probative worth of the evidence on the issue of credibility” — a standard “easy of articulation but troublesome in many cases of application” (see id. at 376 ).

2013As articulated in the well-known Court of Appeals decision in People v Sandoval ( 34 NY2d 371 [1974]), the overriding standard governing the “sound discretion” of the trial judge over the nature and extent of cross-examination (see id. at 374 ) is “whether the prejudicial effect of impeachment testimony far outweighs the probative worth of the evidence on the issue of credibility” — a standard “easy of articulation but troublesome in many cases of application” (see id. at 376 ).

12013–2013
People v. Williams green
nyappdiv · 1983
1 sentence

2005Such a result “conflicts with the defendant’s overriding presumption of innocence as to every element of the crime, and invades the jury’s fact-finding function” (People v Williams, 95 AD2d 866 [1983]; see Sandstrom v Montana, supra; People v Williams, supra at 136).

12005–2005
In re the Accounting of United States Trust Co. green
ny · 1957
1 sentence

2005(Matter of Fabbri, 2 NY2d 236 [1957].) Clearly, Henry N. Kamp knew his son Henry was retarded and intended to provide for him, even to the exclusion of his other children.

12005–2005
Riley v. County of Broome green
ny · 2000
1 sentence

2002The overriding principle of statutory construction is determining legislative intent (Riley v County of Broome, 95 NY2d 455, 463 ; McKinney’s Cons Laws of NY, Book 1, Statutes § 92 [a]).

12002–2002
Ann M. C. v. Orange County Department of Social Services green
nyappdiv · 1998
1 sentence

2000C. v Orange County Dept. of Social Servs., 250 AD2d 190 , lv dismissed 93 NY2d 957 ).

12000–2000
Philips v. Belfi neutral
nyappdiv · 1999
1 sentence

2000Furthermore, in Matter of Chaya S. v Frederick Herbert L. ( 259 AD2d 620 ) the Court specifically upheld the right of a biological mother who consented to a private placement adoption to seek visitation rights with the infant in her status as biological mother as long as the overriding standard in enforcing such rights is the best interests of the child (see also, Matter of Alison D. v Virginia M., 77 NY2d 651 ; Matter of Ann M.

12000–2000
Alison D. v. Virginia M. green
ny · 1991
1 sentence

2000Furthermore, in Matter of Chaya S. v Frederick Herbert L. ( 259 AD2d 620 ) the Court specifically upheld the right of a biological mother who consented to a private placement adoption to seek visitation rights with the infant in her status as biological mother as long as the overriding standard in enforcing such rights is the best interests of the child (see also, Matter of Alison D. v Virginia M., 77 NY2d 651 ; Matter of Ann M.

12000–2000
Lange v. Hoyt green
conn · 1932
1 sentence

1997I charge you that such belief is a factor for you to consider, together with all the other evidence you have heard, in determining whether the plaintiff acted reasonably in caring for her injuries, keeping in mind, however, that the overriding test is whether the plaintiff acted as a reasonably prudent person, under all the circumstances confronting her.” The so-called "reasonable believer” charge (Pomeroy, Reason, Religion, and Avoidable Consequences: When Faith and the Duty to Mitigate Collide, 67 NYU L Rev 1111, 1145-1147 [1992]) has found some support in other jurisdictions (Lange v Hoyt,

11997–1997
Christiansen v. Hollings green
calctapp · 1941
1 sentence

1997I charge you that such belief is a factor for you to consider, together with all the other evidence you have heard, in determining whether the plaintiff acted reasonably in caring for her injuries, keeping in mind, however, that the overriding test is whether the plaintiff acted as a reasonably prudent person, under all the circumstances confronting her.” The so-called "reasonable believer” charge (Pomeroy, Reason, Religion, and Avoidable Consequences: When Faith and the Duty to Mitigate Collide, 67 NYU L Rev 1111, 1145-1147 [1992]) has found some support in other jurisdictions (Lange v Hoyt,

11997–1997
Brearton v. Fina green
nycountyct · 1956
1 sentence

1996(Brearton v Fina, 3 Misc 2d 1 [Franklin County Ct 1956].) As 1 Friedman, Contracts and Conveyances of Real Property § 4.9 (m) (5th ed 1991) explains, "[t]he dominant owner * * * has the duty to repair where he is the user”, in which event the servient owner’s "only obligation [is] to refrain from interfering with * * * proper use” of the easement; but the overriding principle is that "[t]he duty to repair * * * is on the user, being on the servient tenant when he is the user, and on both where the use is shared”.

11996–1996
Rowe v. Great Atlantic & Pacific Tea Co. green
ny · 1978
1 sentence

1992Tea Co., 46 NY2d 62, 68 ).

11992–1992
Kidd v. Merck & Co. green
scotus · 1957
11988–1988
Williams v. Williams green
ny · 1969
11988–1988
Park of Edgewater, Inc. v. Joy neutral
nyappdiv · 1979
11987–1987
Mtr. of Abrams (John Anonymous) green
ny · 1984
11986–1986
People v. Politi yellow
nyappdiv · 1976
11983–1983
People v. Bucksbaum green
nyappdiv · 1976
11983–1983
People v. Gray green
nyappdiv · 1979
11983–1983
People v. Gittelson green
nyappdiv · 1966
11982–1982
WMCA, Inc. v. Lomenzo green
scotus · 1964
11982–1982
Reynolds v. Sims green
scotus · 1964
11982–1982
Zurcher v. Stanford Daily green
scotus · 1978
11982–1982
People v. Gittelson green
ny · 1966
11982–1982
Kirke La Shelle Co. v. Paul Armstrong Co. green
ny · 1933
11981–1981
Van Valkenburgh, Nooger & Neville, Inc. v. Hayden Publishing Co. green
ny · 1972
11981–1981
Boutilier v. Immigration & Naturalization Service green
scotus · 1967
11978–1978
People v. Rutigliano green
ny · 1933
11973–1973
United States Ex Rel. Maine Potato Growers & Shippers Ass'n v. Interstate Commerce Commission green
cadc · 1937
11956–1956
Opp Cotton Mills, Inc. v. Administrator of the Wage & Hour Division of the Department of Labor green
scotus · 1941
11956–1956

Where else courts name it

LA 70 (1974–2024) CA 61 (1972–2026) OH 45 (1983–2026) FL 43 (1961–2025) TX 42 (1982–2023) MI 37 (1966–2026) NY 36 (1956–2024) SC 32 (1986–2023) PA 30 (1966–2026) IL 29 (1964–2020) NJ 28 (1953–2025) MT 23 (1959–2020) VA 23 (1985–2026) WA 22 (1977–2025) MO 16 (1959–2024) IA 14 (1982–2023) WI 13 (1955–2025) TN 12 (1980–2024) MN 11 (1984–2005) OR 10 (1980–2024) CO 9 (1974–2005) CT 9 (1980–2015) MD 9 (1984–2011) NC 8 (1980–2026) AR 7 (1992–2016) MA 7 (1980–2025) KS 7 (1969–2020) UT 7 (1987–2022) KY 6 (1961–2023) RI 6 (2004–2017) NM 5 (1991–2020) ND 4 (1998–2013) GA 4 (1983–2025) ME 4 (1975–2018) AZ 4 (1977–2015) ID 4 (1980–2025) NH 4 (1993–2018) OK 4 (1983–2018) WV 4 (1975–2019) IN 4 (1976–2014) HI 4 (2005–2014) SD 3 (1984–1992) AK 3 (1979–2018) AL 3 (1984–2015) MS 3 (2001–2024) DC 3 (1987–2013)

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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