cumulative effect defense (New York) · Go Syfert
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cumulative effect defense in New York

17 New York opinions name it 1 courts 1998–2025 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 (19)

CaseFollowedCited
People v. Baldigreen
ny · 1981 · cited in 5 New York opinions naming this issue, 2007–2016
2 sentences

2016However, under the circumstances presented, we agree with the defendant that he was deprived of his right to effective assistance of counsel due to the cumulative effect of defense counsel’s failure to seek a severance of the defendant’s trial from that of codefendant David Davydov once it became clear that they were pursuing antagonistic defenses, and failure to request a missing witness charge for an eyewitness who was not called to testify at trial (see People v Mehmood, 112 AD3d 850 [2013]; see also People v Mahboubian, 74 NY2d 174 [1989]; People v Gonzalez, 68 NY2d 424 [1986]; cf. People

2011“We further conclude on the record before us that the cumulative effect of defense counsel’s alleged deficiencies, viewed in totality and as of the time of the representation, did not deprive defendant of effective assistance of counsel” (Marcial, 41 AD3d at 1309 ; see generally People v Satterfield, 66 NY2d 796, 798-799 [1985]; People v Baldi, 54 NY2d 137, 147 [1981]).

35
People v. Bushgreen
nyappdiv · 2013 · cited in 3 New York opinions naming this issue, 2017–2025
2 sentences

2025"While counsel's errors in this regard, individually, may not necessarily rise to the level of ineffective assistance, [*6]we find that the cumulative effect of defense counsel's actions deprived defendant of meaningful representation" ( People v Taylor , 156 AD3d 86, 96 [3d Dept 2017] [footnote, internal quotation marks and citations omitted], lv denied 30 NY3d 1120 [2018]; see People v Bush , 107 AD3d 1302, 1303 [3d Dept 2013]; People v Arnold , 85 AD3d at 1334; People v Miller , 11 AD3d at 730).

2025"While counsel's errors in this regard, individually, may not necessarily rise to the level of ineffective assistance, [*6]we find that the cumulative effect of defense counsel's actions deprived defendant of meaningful representation" ( People v Taylor , 156 AD3d 86, 96 [3d Dept 2017] [footnote, internal quotation marks and citations omitted], lv denied 30 NY3d 1120 [2018]; see People v Bush , 107 AD3d 1302, 1303 [3d Dept 2013]; People v Arnold , 85 AD3d at 1334; People v Miller , 11 AD3d at 730).

33
People v. Arnoldgreen
nyappdiv · 2011 · cited in 3 New York opinions naming this issue, 2016–2017
2 sentences

2017While counsel's errors in this regard, [FN3] individually, may not necessarily rise to the level [*6]of ineffective assistance, we find that "'the cumulative effect of defense counsel's actions deprived defendant of meaningful representation'" ( People v Oathout , 21 NY3d at 132 , quoting People v Arnold , 85 AD3d at 1334 [brackets omitted]; see People v Wright , 25 NY3d at 779 ; People v Bush , 107 AD3d 1302, 1303 [2013]; People v Cantave , 83 AD3d at 859 ; People v Chapman , 54 AD3d 507, 511 [2008]).

2017While counsel’s errors in this regard, 3 individually, may not necessarily rise to the level of ineffective assistance, we find that “ ‘the cumulative effect of defense counsel’s actions deprived defendant of meaningful representation’ ” (People v Oathout, 21 NY3d at 132 [brackets omitted], quoting People v Arnold, 85 AD3d at 1334 ; see People v Wright, 25 NY3d at 779 ; People v Bush, 107 AD3d 1302, 1303 [2013]; People v Cantave, 83 AD3d at 859 ; People v Chapman, 54 AD3d 507, 511 [2008]).

33
The People v. Howard S. Wrightgreen
ny · 2015 · cited in 3 New York opinions naming this issue, 2016–2017
2 sentences

2017While counsel's errors in this regard, [FN3] individually, may not necessarily rise to the level [*6]of ineffective assistance, we find that "'the cumulative effect of defense counsel's actions deprived defendant of meaningful representation'" ( People v Oathout , 21 NY3d at 132 , quoting People v Arnold , 85 AD3d at 1334 [brackets omitted]; see People v Wright , 25 NY3d at 779 ; People v Bush , 107 AD3d 1302, 1303 [2013]; People v Cantave , 83 AD3d at 859 ; People v Chapman , 54 AD3d 507, 511 [2008]).

2017While counsel’s errors in this regard, 3 individually, may not necessarily rise to the level of ineffective assistance, we find that “ ‘the cumulative effect of defense counsel’s actions deprived defendant of meaningful representation’ ” (People v Oathout, 21 NY3d at 132 [brackets omitted], quoting People v Arnold, 85 AD3d at 1334 ; see People v Wright, 25 NY3d at 779 ; People v Bush, 107 AD3d 1302, 1303 [2013]; People v Cantave, 83 AD3d at 859 ; People v Chapman, 54 AD3d 507, 511 [2008]).

33
People v. Satterfieldgreen
ny · 1985 · cited in 3 New York opinions naming this issue, 2007–2011
2 sentences

2011“We further conclude on the record before us that the cumulative effect of defense counsel’s alleged deficiencies, viewed in totality and as of the time of the representation, did not deprive defendant of effective assistance of counsel” (Marcial, 41 AD3d at 1309 ; see generally People v Satterfield, 66 NY2d 796, 798-799 [1985]; People v Baldi, 54 NY2d 137, 147 [1981]).

2011“We further conclude on the record before us that the cumulative effect of defense counsel’s alleged deficiencies, viewed in totality and as of the time of the representation, did not deprive defendant of effective assistance of counsel” (Marcial, 41 AD3d at 1309 ; see generally People v Satterfield, 66 NY2d 796, 798-799 ; People v Baldi, 54 NY2d 137, 147 ).

33
People v. Clarkegreen
nyappdiv · 2009 · cited in 4 New York opinions naming this issue, 2010–2025
2 sentences

2025"This is especially so where, as here, the determination of guilt . . . hinged on sharp issues of credibility" ( People v Clarke , 66 AD3d 694, 698 [2d Dept 2009] [citations omitted]; see People v Taylor , 156 AD3d at 97).

2010The cumulative effect of defense counsel’s errors deprived the defendant of meaningful representation and a fair trial (see People v Benevento, 91 NY2d 708, 712 [1998]; People v Clarke, 66 AD3d 694, 698 [2009]; People v Jeannot, 59 AD3d 737 [2009]).

24
People v. Chapmangreen
nyappdiv · 2008 · cited in 2 New York opinions naming this issue, 2017–2017
2 sentences

2017While counsel's errors in this regard, [FN3] individually, may not necessarily rise to the level [*6]of ineffective assistance, we find that "'the cumulative effect of defense counsel's actions deprived defendant of meaningful representation'" ( People v Oathout , 21 NY3d at 132 , quoting People v Arnold , 85 AD3d at 1334 [brackets omitted]; see People v Wright , 25 NY3d at 779 ; People v Bush , 107 AD3d 1302, 1303 [2013]; People v Cantave , 83 AD3d at 859 ; People v Chapman , 54 AD3d 507, 511 [2008]).

2017While counsel’s errors in this regard, 3 individually, may not necessarily rise to the level of ineffective assistance, we find that “ ‘the cumulative effect of defense counsel’s actions deprived defendant of meaningful representation’ ” (People v Oathout, 21 NY3d at 132 [brackets omitted], quoting People v Arnold, 85 AD3d at 1334 ; see People v Wright, 25 NY3d at 779 ; People v Bush, 107 AD3d 1302, 1303 [2013]; People v Cantave, 83 AD3d at 859 ; People v Chapman, 54 AD3d 507, 511 [2008]).

22
People v. Cassalagreen
nyappdiv · 2015 · cited in 2 New York opinions naming this issue, 2017–2017
2 sentences

2017"This is especially so where, as here, the determination of guilt . . . hinged on sharp issues of credibility" ( People v Clarke , 66 AD3d at 698 ; accord People v Cassala , 130 AD3d at 1257 ).

2017“This is especially so where, as here, the determination of guilt . . . hinged on sharp issues of credibility” (People v Clarke, 66 AD3d at 698 ; accord People v Cassala, 130 AD3d at 1257 ).

22
People v. Danrajgreen
nyappdiv · 2010 · cited in 2 New York opinions naming this issue, 2012–2012
2 sentences

2012The cumulative effect of defense counsel’s errors deprived the defendant of the effective assistance of counsel (see People v Danraj, 75 AD3d 651, 652 [2010]; People v Brown, 300 AD2d 314, 315 [2002]).

2012The cumulative effect of defense counsel’s errors deprived the defendant of the effective assistance of counsel (see People v Danraj, 75 AD3d 651, 652 [2010]; People v Brown, 300 AD2d 314, 315 [2002]).

22
People v. Briggsgreen
nyappdiv · 2002 · cited in 2 New York opinions naming this issue, 2012–2012
2 sentences

2012The cumulative effect of defense counsel’s errors deprived the defendant of the effective assistance of counsel (see People v Danraj, 75 AD3d 651, 652 [2010]; People v Brown, 300 AD2d 314, 315 [2002]).

2012The cumulative effect of defense counsel’s errors deprived the defendant of the effective assistance of counsel (see People v Danraj, 75 AD3d 651, 652 [2010]; People v Brown, 300 AD2d 314, 315 [2002]).

22
People v. Oathoutgreen
ny · 2013 · cited in 2 New York opinions naming this issue, 2017–2017
2 sentences

2017While counsel's errors in this regard, [FN3] individually, may not necessarily rise to the level [*6]of ineffective assistance, we find that "'the cumulative effect of defense counsel's actions deprived defendant of meaningful representation'" ( People v Oathout , 21 NY3d at 132 , quoting People v Arnold , 85 AD3d at 1334 [brackets omitted]; see People v Wright , 25 NY3d at 779 ; People v Bush , 107 AD3d 1302, 1303 [2013]; People v Cantave , 83 AD3d at 859 ; People v Chapman , 54 AD3d 507, 511 [2008]).

2017While counsel’s errors in this regard, 3 individually, may not necessarily rise to the level of ineffective assistance, we find that “ ‘the cumulative effect of defense counsel’s actions deprived defendant of meaningful representation’ ” (People v Oathout, 21 NY3d at 132 [brackets omitted], quoting People v Arnold, 85 AD3d at 1334 ; see People v Wright, 25 NY3d at 779 ; People v Bush, 107 AD3d 1302, 1303 [2013]; People v Cantave, 83 AD3d at 859 ; People v Chapman, 54 AD3d 507, 511 [2008]).

12
People v. Beneventogreen
ny · 1998 · cited in 2 New York opinions naming this issue, 2010–2016
2 sentences

2016However, under the circumstances presented, we agree with the defendant that he was deprived of his right to effective assistance of counsel due to the cumulative effect of defense counsel’s failure to seek a severance of the defendant’s trial from that of codefendant David Davydov once it became clear that they were pursuing antagonistic defenses, and failure to request a missing witness charge for an eyewitness who was not called to testify at trial (see People v Mehmood, 112 AD3d 850 [2013]; see also People v Mahboubian, 74 NY2d 174 [1989]; People v Gonzalez, 68 NY2d 424 [1986]; cf. People

2010The cumulative effect of defense counsel’s errors deprived the defendant of meaningful representation and a fair trial (see People v Benevento, 91 NY2d 708, 712 [1998]; People v Clarke, 66 AD3d 694, 698 [2009]; People v Jeannot, 59 AD3d 737 [2009]).

12
Kelly v. Metropolitan Insurance & Annuity Co.green
nyappdiv · 2011 · cited in 1 New York opinions naming this issue, 2025–2025
2 sentences

2025The cumulative effect of this error, superimposed on the erroneous inclusion of evidence related to and consideration of time-barred loans and other transactions, as set forth below, requires a new trial ( see Kelly v Metropolitan Ins. & Annuity Co ., 82 AD3d 16, 24 [1st Dept 2011]; Collier v Postum Cereal Co ., 149 App Div 143 [1st Dept 1912]). [FN19] Justices Moulton and Friedman take issue with the remedy we believe is appropriate under the law: a new trial.

2025The cumulative effect of this error, superimposed on the erroneous inclusion of evidence related to and consideration of time-barred loans and other transactions, as set forth below, requires a new trial ( see Kelly v Metropolitan Ins. & Annuity Co ., 82 AD3d 16, 24 [1st Dept 2011]; Collier v Postum Cereal Co ., 149 App Div 143 [1st Dept 1912]). [FN19] Justices Moulton and Friedman take issue with the remedy we believe is appropriate under the law: a new trial.

11
People v. Taylorgreen
nyappdiv · 2017 · cited in 1 New York opinions naming this issue, 2025–2025
2 sentences

2025"While counsel's errors in this regard, individually, may not necessarily rise to the level of ineffective assistance, [*6]we find that the cumulative effect of defense counsel's actions deprived defendant of meaningful representation" ( People v Taylor , 156 AD3d 86, 96 [3d Dept 2017] [footnote, internal quotation marks and citations omitted], lv denied 30 NY3d 1120 [2018]; see People v Bush , 107 AD3d 1302, 1303 [3d Dept 2013]; People v Arnold , 85 AD3d at 1334; People v Miller , 11 AD3d at 730).

2025"While counsel's errors in this regard, individually, may not necessarily rise to the level of ineffective assistance, [*6]we find that the cumulative effect of defense counsel's actions deprived defendant of meaningful representation" ( People v Taylor , 156 AD3d 86, 96 [3d Dept 2017] [footnote, internal quotation marks and citations omitted], lv denied 30 NY3d 1120 [2018]; see People v Bush , 107 AD3d 1302, 1303 [3d Dept 2013]; People v Arnold , 85 AD3d at 1334; People v Miller , 11 AD3d at 730).

11
People v. Millergreen
nyappdiv · 2004 · cited in 1 New York opinions naming this issue, 2025–2025
2 sentences

2025"While counsel's errors in this regard, individually, may not necessarily rise to the level of ineffective assistance, [*6]we find that the cumulative effect of defense counsel's actions deprived defendant of meaningful representation" ( People v Taylor , 156 AD3d 86, 96 [3d Dept 2017] [footnote, internal quotation marks and citations omitted], lv denied 30 NY3d 1120 [2018]; see People v Bush , 107 AD3d 1302, 1303 [3d Dept 2013]; People v Arnold , 85 AD3d at 1334; People v Miller , 11 AD3d at 730).

2025"While counsel's errors in this regard, individually, may not necessarily rise to the level of ineffective assistance, [*6]we find that the cumulative effect of defense counsel's actions deprived defendant of meaningful representation" ( People v Taylor , 156 AD3d 86, 96 [3d Dept 2017] [footnote, internal quotation marks and citations omitted], lv denied 30 NY3d 1120 [2018]; see People v Bush , 107 AD3d 1302, 1303 [3d Dept 2013]; People v Arnold , 85 AD3d at 1334; People v Miller , 11 AD3d at 730).

11
People v. Mahboubiangreen
ny · 1989 · cited in 1 New York opinions naming this issue, 2016–2016
1 sentence

2016However, under the circumstances presented, we agree with the defendant that he was deprived of his right to effective assistance of counsel due to the cumulative effect of defense counsel’s failure to seek a severance of the defendant’s trial from that of codefendant David Davydov once it became clear that they were pursuing antagonistic defenses, and failure to request a missing witness charge for an eyewitness who was not called to testify at trial (see People v Mehmood, 112 AD3d 850 [2013]; see also People v Mahboubian, 74 NY2d 174 [1989]; People v Gonzalez, 68 NY2d 424 [1986]; cf. People

11
Strickland v. Washingtongreen
scotus · 1984 · cited in 1 New York opinions naming this issue, 2016–2016
1 sentence

2016“Under the federal standard for ineffective assistance of counsel, a defendant must show that his or her attorney’s performance fell below an objective standard of reasonableness, and that ‘there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different’ ” (People v Bodden, 82 AD3d 781 , 783 [2011], quoting Strickland v Washington, 466 US 668, 694 [1984]).

11
People v. Turnergreen
ny · 2005 · cited in 1 New York opinions naming this issue, 2016–2016
1 sentence

2016However, under the circumstances presented, we agree with the defendant that he was deprived of his right to effective assistance of counsel due to the cumulative effect of defense counsel’s failure to seek a severance of the defendant’s trial from that of codefendant David Davydov once it became clear that they were pursuing antagonistic defenses, and failure to request a missing witness charge for an eyewitness who was not called to testify at trial (see People v Mehmood, 112 AD3d 850 [2013]; see also People v Mahboubian, 74 NY2d 174 [1989]; People v Gonzalez, 68 NY2d 424 [1986]; cf. People

11
People v. Bleakleygreen
ny · 1987 · cited in 1 New York opinions naming this issue, 2008–2008
1 sentence

2008Contrary to defendant’s further contentions, the verdict is not against the weight of the evidence with respect to assault in the second degree under counts four and five of the indictment (see generally People v Bleakley, 69 NY2d 490, 495 [1987]), and the sentence is not unduly harsh or severe.

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 (12)

CaseCitedYears
People v. Marcial green
nyappdiv · 2007
2 sentences

2011“We further conclude on the record before us that the cumulative effect of defense counsel’s alleged deficiencies, viewed in totality and as of the time of the representation, did not deprive defendant of effective assistance of counsel” (Marcial, 41 AD3d at 1309 ; see generally People v Satterfield, 66 NY2d 796, 798-799 [1985]; People v Baldi, 54 NY2d 137, 147 [1981]).

2011“We further conclude on the record before us that the cumulative effect of defense counsel’s alleged deficiencies, viewed in totality and as of the time of the representation, did not deprive defendant of effective assistance of counsel” (Marcial, 41 AD3d at 1309 ; see generally People v Satterfield, 66 NY2d 796, 798-799 ; People v Baldi, 54 NY2d 137, 147 ).

32008–2011
People v. Cantave green
nyappdiv · 2011
2 sentences

2017While counsel's errors in this regard, [FN3] individually, may not necessarily rise to the level [*6]of ineffective assistance, we find that "'the cumulative effect of defense counsel's actions deprived defendant of meaningful representation'" ( People v Oathout , 21 NY3d at 132 , quoting People v Arnold , 85 AD3d at 1334 [brackets omitted]; see People v Wright , 25 NY3d at 779 ; People v Bush , 107 AD3d 1302, 1303 [2013]; People v Cantave , 83 AD3d at 859 ; People v Chapman , 54 AD3d 507, 511 [2008]).

2017While counsel’s errors in this regard, 3 individually, may not necessarily rise to the level of ineffective assistance, we find that “ ‘the cumulative effect of defense counsel’s actions deprived defendant of meaningful representation’ ” (People v Oathout, 21 NY3d at 132 [brackets omitted], quoting People v Arnold, 85 AD3d at 1334 ; see People v Wright, 25 NY3d at 779 ; People v Bush, 107 AD3d 1302, 1303 [2013]; People v Cantave, 83 AD3d at 859 ; People v Chapman, 54 AD3d 507, 511 [2008]).

22017–2017
People v. McArthur green
nyappdiv · 2012
2 sentences

2013The cumulative effect of defense counsel’s errors deprived the defendant of the effective assistance of counsel (see People v McArthur, 101 AD3d at 754 ).

2013The cumulative effect of defense counsel’s errors deprived the defendant of the effective assistance of counsel (see People v McArthur, 101 AD3d at 754 ).

22013–2013
Collier v. Postum Cereal Co. green
nyappdiv · 1912
2 sentences

2025The cumulative effect of this error, superimposed on the erroneous inclusion of evidence related to and consideration of time-barred loans and other transactions, as set forth below, requires a new trial ( see Kelly v Metropolitan Ins. & Annuity Co ., 82 AD3d 16, 24 [1st Dept 2011]; Collier v Postum Cereal Co ., 149 App Div 143 [1st Dept 1912]). [FN19] Justices Moulton and Friedman take issue with the remedy we believe is appropriate under the law: a new trial.

2025The cumulative effect of this error, superimposed on the erroneous inclusion of evidence related to and consideration of time-barred loans and other transactions, as set forth below, requires a new trial ( see Kelly v Metropolitan Ins. & Annuity Co ., 82 AD3d 16, 24 [1st Dept 2011]; Collier v Postum Cereal Co ., 149 App Div 143 [1st Dept 1912]). [FN19] Justices Moulton and Friedman take issue with the remedy we believe is appropriate under the law: a new trial.

12025–2025
People v. Travis green
nycterr · 2018
2 sentences

2025"While counsel's errors in this regard, individually, may not necessarily rise to the level of ineffective assistance, [*6]we find that the cumulative effect of defense counsel's actions deprived defendant of meaningful representation" ( People v Taylor , 156 AD3d 86, 96 [3d Dept 2017] [footnote, internal quotation marks and citations omitted], lv denied 30 NY3d 1120 [2018]; see People v Bush , 107 AD3d 1302, 1303 [3d Dept 2013]; People v Arnold , 85 AD3d at 1334; People v Miller , 11 AD3d at 730).

2025"While counsel's errors in this regard, individually, may not necessarily rise to the level of ineffective assistance, [*6]we find that the cumulative effect of defense counsel's actions deprived defendant of meaningful representation" ( People v Taylor , 156 AD3d 86, 96 [3d Dept 2017] [footnote, internal quotation marks and citations omitted], lv denied 30 NY3d 1120 [2018]; see People v Bush , 107 AD3d 1302, 1303 [3d Dept 2013]; People v Arnold , 85 AD3d at 1334; People v Miller , 11 AD3d at 730).

12025–2025
People v. Shelton green
nyappdiv · 2015
1 sentence

2022The totality of the circumstances, including the cumulative effect of the factors relied upon by the defendant, did not show that the presumptive risk level overassessed the defendant's risk and danger of reoffense ( see People v Aller , 164 AD3d 1381 , 1382; People v Tromba , 157 AD3d 915 , 916; People v Shelton , 126 AD3d 959, 960 ).

12022–2022
People v. Bodden green
nyappdiv · 2011
1 sentence

2016“Under the federal standard for ineffective assistance of counsel, a defendant must show that his or her attorney’s performance fell below an objective standard of reasonableness, and that ‘there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different’ ” (People v Bodden, 82 AD3d 781 , 783 [2011], quoting Strickland v Washington, 466 US 668, 694 [1984]).

12016–2016
People v. Mehmood green
nyappdiv · 2013
1 sentence

2016However, under the circumstances presented, we agree with the defendant that he was deprived of his right to effective assistance of counsel due to the cumulative effect of defense counsel’s failure to seek a severance of the defendant’s trial from that of codefendant David Davydov once it became clear that they were pursuing antagonistic defenses, and failure to request a missing witness charge for an eyewitness who was not called to testify at trial (see People v Mehmood, 112 AD3d 850 [2013]; see also People v Mahboubian, 74 NY2d 174 [1989]; People v Gonzalez, 68 NY2d 424 [1986]; cf. People

12016–2016
People v. Gonzalez green
ny · 1986
1 sentence

2016However, under the circumstances presented, we agree with the defendant that he was deprived of his right to effective assistance of counsel due to the cumulative effect of defense counsel’s failure to seek a severance of the defendant’s trial from that of codefendant David Davydov once it became clear that they were pursuing antagonistic defenses, and failure to request a missing witness charge for an eyewitness who was not called to testify at trial (see People v Mehmood, 112 AD3d 850 [2013]; see also People v Mahboubian, 74 NY2d 174 [1989]; People v Gonzalez, 68 NY2d 424 [1986]; cf. People

12016–2016
People v. Jeannot green
nyappdiv · 2009
1 sentence

2010The cumulative effect of defense counsel’s errors deprived the defendant of meaningful representation and a fair trial (see People v Benevento, 91 NY2d 708, 712 [1998]; People v Clarke, 66 AD3d 694, 698 [2009]; People v Jeannot, 59 AD3d 737 [2009]).

12010–2010
Torrado v. Lutheran Medical Center green
nyappdiv · 1993
11998–1998
Bacigalupo v. Healthshield, Inc. green
nyappdiv · 1996
1 sentence

1998The plaintiffs’ claims that the cumulative effect of the defense counsel’s arguments and remarks, as well as of certain gratuitous comments of the trial court, operated to deprive them of a fair trial, are unpreserved for appellate review and are, in any event, without merit (see, Bacigalupo v Healthshield, Inc., 231 AD2d 538; Torrado v Lutheran Med.

11998–1998

Statutes the citing opinions construe

NY § N.Y. Penal Law § 120.05 (3) NY § N.Y. Penal Law § 130.00 (3) 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

KS 124 (1992–2024) AL 40 (1999–2026) PA 19 (2008–2026) NY 17 (1998–2025) TX 17 (1974–2024) OH 16 (1991–2025) IL 15 (1974–2022) CA 13 (1978–2023) MI 5 (2015–2025) WI 5 (1954–2024) IA 5 (1996–2024) TN 5 (1988–2024) FL 5 (1989–2013) IN 4 (2012–2018) MS 4 (2000–2005) WV 4 (1980–2023) AZ 4 (1992–2026) NJ 3 (1975–1996) KY 3 (1958–2026) MN 3 (1984–2006) ND 2 (2011–2011) MA 2 (1999–2024) MD 2 (2020–2021) GA 2 (2016–2021) WA 2 (2016–2024) MO 2 (1973–1983) SD 2 (1990–1995)

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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