parallel rule (New York) · Go Syfert
← New York issues

parallel rule in New York

14 New York opinions name it 4 courts 1954–2025 1 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 (18)

CaseFollowedCited
People v. Baumann & Sons Buses, Inc.green
ny · 2006 · cited in 1 New York opinions naming this issue, 2025–2025
2 sentences

2025As an alternative holding, we find that defendant's constitutional claim, which asks us to construe the address reporting requirement in Correction Law § 168-f(4) in the same manner as we did the parallel requirement in subsection 168-f(3) in Allen , is unpreserved ( see People v Bauman & Sons Buses, Inc. , 6 NY3d 404, 408 [2006]; People v Allen, 206 AD3d 539 [1st Dept 2022], appeal decided by 213 AD3d 73 [1st Dept 2023]).

2025As an alternative holding, we find that defendant's constitutional claim, which asks us to construe the address reporting requirement in Correction Law § 168-f(4) in the same manner as we did the parallel requirement in subsection 168-f(3) in Allen , is unpreserved ( see People v Bauman & Sons Buses, Inc. , 6 NY3d 404, 408 [2006]; People v Allen, 206 AD3d 539 [1st Dept 2022], appeal decided by 213 AD3d 73 [1st Dept 2023]).

11
Hess v. Mack Trucks, Inc.green
nyappdiv · 1990 · cited in 1 New York opinions naming this issue, 2016–2016
2 sentences

2016Furthermore, for years, Appellate Division decisions have held that a manufacturer has a duty to warn about the dangers resulting from the combined use of its product with another product that is essential to the intended function of the manufacturer’s product (see Baum v Eco-Tec, Inc., 5 AD3d 842, 845 [3d Dept 2004]; Berhowitz v A.C. & S., Inc., 288 AD2d 148, 149 [1st Dept 2001]; Rogers v Sears, Roebuck & Co., 268 AD2d 245, 246 [1st Dept 2000]; Village of Groton v Tokheim Corp., 202 AD2d 728, 729-730 [3d Dept 1994]; cf. Hess v Mack Trucks, 159 AD2d 557, 558 [2d Dept 1990]).

2016Furthermore, for years, Appellate Division decisions have held that a manufacturer has a duty to warn about the dangers resulting from the combined use of its product with another product that is essential to the intended function of the manufacturer's product (see Baum v Eco-Tec, Inc., 5 AD3d 842, 845 [3d Dept 2004]; Berkowitz v. A.C. & S., Inc., 288 AD2d 148, 149 [1st Dept 2001]; Rogers v Sears, Roebuck & Co., 268 AD2d 245, 246 [1st Dept 2000]; Village of Groton v Tokheim Corp., 202 AD2d 728, 729-730 [3d Dept 1984]; cf. Hess v Mack Trucks, 159 AD2d 557, 558 [2d Dept 1990]).

11
Village of Groton v. Tokheim Corp.green
nyappdiv · 1994 · cited in 1 New York opinions naming this issue, 2016–2016
2 sentences

2016Furthermore, for years, Appellate Division decisions have held that a manufacturer has a duty to warn about the dangers resulting from the combined use of its product with another product that is essential to the intended function of the manufacturer’s product (see Baum v Eco-Tec, Inc., 5 AD3d 842, 845 [3d Dept 2004]; Berhowitz v A.C. & S., Inc., 288 AD2d 148, 149 [1st Dept 2001]; Rogers v Sears, Roebuck & Co., 268 AD2d 245, 246 [1st Dept 2000]; Village of Groton v Tokheim Corp., 202 AD2d 728, 729-730 [3d Dept 1994]; cf. Hess v Mack Trucks, 159 AD2d 557, 558 [2d Dept 1990]).

2016Furthermore, for years, Appellate Division decisions have held that a manufacturer has a duty to warn about the dangers resulting from the combined use of its product with another product that is essential to the intended function of the manufacturer's product (see Baum v Eco-Tec, Inc., 5 AD3d 842, 845 [3d Dept 2004]; Berkowitz v. A.C. & S., Inc., 288 AD2d 148, 149 [1st Dept 2001]; Rogers v Sears, Roebuck & Co., 268 AD2d 245, 246 [1st Dept 2000]; Village of Groton v Tokheim Corp., 202 AD2d 728, 729-730 [3d Dept 1984]; cf. Hess v Mack Trucks, 159 AD2d 557, 558 [2d Dept 1990]).

11
Baum v. Eco-Tec, Inc.green
nyappdiv · 2004 · cited in 1 New York opinions naming this issue, 2016–2016
2 sentences

2016Furthermore, for years, Appellate Division decisions have held that a manufacturer has a duty to warn about the dangers resulting from the combined use of its product with another product that is essential to the intended function of the manufacturer’s product (see Baum v Eco-Tec, Inc., 5 AD3d 842, 845 [3d Dept 2004]; Berhowitz v A.C. & S., Inc., 288 AD2d 148, 149 [1st Dept 2001]; Rogers v Sears, Roebuck & Co., 268 AD2d 245, 246 [1st Dept 2000]; Village of Groton v Tokheim Corp., 202 AD2d 728, 729-730 [3d Dept 1994]; cf. Hess v Mack Trucks, 159 AD2d 557, 558 [2d Dept 1990]).

2016Furthermore, for years, Appellate Division decisions have held that a manufacturer has a duty to warn about the dangers resulting from the combined use of its product with another product that is essential to the intended function of the manufacturer's product (see Baum v Eco-Tec, Inc., 5 AD3d 842, 845 [3d Dept 2004]; Berkowitz v. A.C. & S., Inc., 288 AD2d 148, 149 [1st Dept 2001]; Rogers v Sears, Roebuck & Co., 268 AD2d 245, 246 [1st Dept 2000]; Village of Groton v Tokheim Corp., 202 AD2d 728, 729-730 [3d Dept 1984]; cf. Hess v Mack Trucks, 159 AD2d 557, 558 [2d Dept 1990]).

11
Rogers v. Sears, Roebuck & Co.green
nyappdiv · 2000 · cited in 1 New York opinions naming this issue, 2016–2016
2 sentences

2016Furthermore, for years, Appellate Division decisions have held that a manufacturer has a duty to warn about the dangers resulting from the combined use of its product with another product that is essential to the intended function of the manufacturer’s product (see Baum v Eco-Tec, Inc., 5 AD3d 842, 845 [3d Dept 2004]; Berhowitz v A.C. & S., Inc., 288 AD2d 148, 149 [1st Dept 2001]; Rogers v Sears, Roebuck & Co., 268 AD2d 245, 246 [1st Dept 2000]; Village of Groton v Tokheim Corp., 202 AD2d 728, 729-730 [3d Dept 1994]; cf. Hess v Mack Trucks, 159 AD2d 557, 558 [2d Dept 1990]).

2016Furthermore, for years, Appellate Division decisions have held that a manufacturer has a duty to warn about the dangers resulting from the combined use of its product with another product that is essential to the intended function of the manufacturer's product (see Baum v Eco-Tec, Inc., 5 AD3d 842, 845 [3d Dept 2004]; Berkowitz v. A.C. & S., Inc., 288 AD2d 148, 149 [1st Dept 2001]; Rogers v Sears, Roebuck & Co., 268 AD2d 245, 246 [1st Dept 2000]; Village of Groton v Tokheim Corp., 202 AD2d 728, 729-730 [3d Dept 1984]; cf. Hess v Mack Trucks, 159 AD2d 557, 558 [2d Dept 1990]).

11
Berkowitz v. A.C. & S., Inc.green
nyappdiv · 2001 · cited in 1 New York opinions naming this issue, 2016–2016
2 sentences

2016Furthermore, for years, Appellate Division decisions have held that a manufacturer has a duty to warn about the dangers resulting from the combined use of its product with another product that is essential to the intended function of the manufacturer’s product (see Baum v Eco-Tec, Inc., 5 AD3d 842, 845 [3d Dept 2004]; Berhowitz v A.C. & S., Inc., 288 AD2d 148, 149 [1st Dept 2001]; Rogers v Sears, Roebuck & Co., 268 AD2d 245, 246 [1st Dept 2000]; Village of Groton v Tokheim Corp., 202 AD2d 728, 729-730 [3d Dept 1994]; cf. Hess v Mack Trucks, 159 AD2d 557, 558 [2d Dept 1990]).

2016Furthermore, for years, Appellate Division decisions have held that a manufacturer has a duty to warn about the dangers resulting from the combined use of its product with another product that is essential to the intended function of the manufacturer's product (see Baum v Eco-Tec, Inc., 5 AD3d 842, 845 [3d Dept 2004]; Berkowitz v. A.C. & S., Inc., 288 AD2d 148, 149 [1st Dept 2001]; Rogers v Sears, Roebuck & Co., 268 AD2d 245, 246 [1st Dept 2000]; Village of Groton v Tokheim Corp., 202 AD2d 728, 729-730 [3d Dept 1984]; cf. Hess v Mack Trucks, 159 AD2d 557, 558 [2d Dept 1990]).

11
Parker v. Stryker Corp.green
cod · 2008 · cited in 1 New York opinions naming this issue, 2008–2008
1 sentence

2008While not raised by plaintiff, the alleged failure of Urologix to comply with the MDA’s reporting requirements does not constitute a “parallel claim” which would escape preemption (Riegel, 552 US at —, 128 S Ct at 1011 ), because such an allegation would merely be an attempt to recast plaintiffs state law claims as violations of federal statutes (see Parker, 584 F Supp 2d at 1301 [an FDA finding that a class III device is “adulterated” within the meaning of 21 USC § 351 (h) is insufficient to support a parallel claim under the MDA]).

11
In re David T.green
ny · 1990 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004In People v Alejandro ( 70 NY2d 133, 138 [1987]), the Court held that “an information must, for jurisdictional purposes, contain nonhearsay factual allegations sufficient to establish a prima facie case.” In interpreting its own holding in Alejandro , the Court held that, where a juvenile delinquency petition fails to contain non-hearsay allegations sufficient to support each element of the crime charged, “an omission of this nature in a criminal information renders the accusatory instrument jurisdictionally defective” (Matter of David T., 75 NY2d 927, 928 [1990]; see generally Jahron S., 79 N

11
In re Jahron S.green
ny · 1992 · cited in 1 New York opinions naming this issue, 2004–2004
2 sentences

2004Pursuant to section 311.2 (3) a petition in a juvenile delinquency proceeding is sufficient on its face when “non-hearsay allegations of the factual part of the petition or of any supporting depositions establish, if true, every element of each crime charged and the respondent’s commission thereof.” The Court of Appeals has held that section 311.2 (3) should be interpreted the same way as CPL 100.40 (1) (c), which has a parallel requirement for misdemeanor informations (see Matter of Edward B., 80 NY2d 458, 464 [1992]; Matter of Jahron S., 79 NY2d 632, 636-637 [1992]; see also Matter of Desmon

2004In People v Alejandro ( 70 NY2d 133, 138 [1987]), the Court held that “an information must, for jurisdictional purposes, contain nonhearsay factual allegations sufficient to establish a prima facie case.” In interpreting its own holding in Alejandro , the Court held that, where a juvenile delinquency petition fails to contain non-hearsay allegations sufficient to support each element of the crime charged, “an omission of this nature in a criminal information renders the accusatory instrument jurisdictionally defective” (Matter of David T., 75 NY2d 927, 928 [1990]; see generally Jahron S., 79 N

11
In re Edward B.green
ny · 1992 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004Pursuant to section 311.2 (3) a petition in a juvenile delinquency proceeding is sufficient on its face when “non-hearsay allegations of the factual part of the petition or of any supporting depositions establish, if true, every element of each crime charged and the respondent’s commission thereof.” The Court of Appeals has held that section 311.2 (3) should be interpreted the same way as CPL 100.40 (1) (c), which has a parallel requirement for misdemeanor informations (see Matter of Edward B., 80 NY2d 458, 464 [1992]; Matter of Jahron S., 79 NY2d 632, 636-637 [1992]; see also Matter of Desmon

11
In re Desmond J.green
nyappdiv · 1998 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004Pursuant to section 311.2 (3) a petition in a juvenile delinquency proceeding is sufficient on its face when “non-hearsay allegations of the factual part of the petition or of any supporting depositions establish, if true, every element of each crime charged and the respondent’s commission thereof.” The Court of Appeals has held that section 311.2 (3) should be interpreted the same way as CPL 100.40 (1) (c), which has a parallel requirement for misdemeanor informations (see Matter of Edward B., 80 NY2d 458, 464 [1992]; Matter of Jahron S., 79 NY2d 632, 636-637 [1992]; see also Matter of Desmon

11
In re the Estate of Antoinettegreen
nyappdiv · 2002 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004The parallel doctrine of collateral estoppel, or issue preclusion, further “ ‘precludes a party from relitigating in a subsequent . . . proceeding an issue clearly raised in a prior . . . proceeding and decided against that party . . ., whether or not the . . . causes of action are the same’ ” (Matter of Antoinette, 291 AD2d 733, 734 [2002], lv denied 98 NY2d 604 [2002], quoting Ryan v New York Tel.

11
Matter of Desmond J.green
ny · 1999 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004Pursuant to section 311.2 (3) a petition in a juvenile delinquency proceeding is sufficient on its face when “non-hearsay allegations of the factual part of the petition or of any supporting depositions establish, if true, every element of each crime charged and the respondent’s commission thereof.” The Court of Appeals has held that section 311.2 (3) should be interpreted the same way as CPL 100.40 (1) (c), which has a parallel requirement for misdemeanor informations (see Matter of Edward B., 80 NY2d 458, 464 [1992]; Matter of Jahron S., 79 NY2d 632, 636-637 [1992]; see also Matter of Desmon

11
Ryan v. New York Telephone Co.green
ny · 1984 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004Co., 62 NY2d 494, 500 [1984]).

11
People v. Alejandrogreen
ny · 1987 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004In People v Alejandro ( 70 NY2d 133, 138 [1987]), the Court held that “an information must, for jurisdictional purposes, contain nonhearsay factual allegations sufficient to establish a prima facie case.” In interpreting its own holding in Alejandro , the Court held that, where a juvenile delinquency petition fails to contain non-hearsay allegations sufficient to support each element of the crime charged, “an omission of this nature in a criminal information renders the accusatory instrument jurisdictionally defective” (Matter of David T., 75 NY2d 927, 928 [1990]; see generally Jahron S., 79 N

11
United States v. X-Citement Video, Inc.green
scotus · 1994 · cited in 1 New York opinions naming this issue, 1998–1998
2 sentences

1998(United States v X-Citement Video, supra.) However, a parallel analysis of Penal Law § 263.16 demonstrates that it was the intention of the New York State Legislature to impose strict liability on those persons who are proven to know both the character and content of sexual performances in their possession which utilize children under the age of 16.

1998(See also, Penal Law § 15.20 [3].) Accordingly, the “presumption [cited in X-Citement] in favor of [applying] a scienter requirement * * * to each of the statutory elements that criminalize otherwise innocent conduct” (United States v X-Citement Video, supra, at 72) is inapplicable to this case.

11
Burns v. . McCormickgreen
ny · 1922 · cited in 1 New York opinions naming this issue, 1977–1977
11
Bakhshandeh v. American Cyanamid Co.green
nyappdiv · 1959 · cited in 1 New York opinions naming this issue, 1977–1977
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 (34)

CaseCitedYears
Sage v. Fairchild-Swearingen Corp. green
ny · 1987
2 sentences

2016Likewise, in Sage v Fairchild-Swearingen Corp. ( 70 NY2d 579 [1987]), we recognized a parallel principle in the somewhat related design defect context, 7 ruling that a company which designed and manufactured an airplane and a hook on the plane’s ladder could be held liable for injuries caused by a replacement hook made by someone else in accordance with the original manufacturer’s unsafe design (see Sage, 70 NY2d at 586-588 ).

2016Likewise, in Sage v Fairchild-Swearingen Corp. ( 70 NY2d 579 [1987]), we recognized a parallel principle in the somewhat related design defect context, 7 ruling that a company which designed and manufactured an airplane and a hook on the plane’s ladder could be held liable for injuries caused by a replacement hook made by someone else in accordance with the original manufacturer’s unsafe design (see Sage, 70 NY2d at 586-588 ).

12016–2016
Riegel v. Medtronic, Inc. green
scotus · 2008
1 sentence

2008While not raised by plaintiff, the alleged failure of Urologix to comply with the MDA’s reporting requirements does not constitute a “parallel claim” which would escape preemption (Riegel, 552 US at —, 128 S Ct at 1011 ), because such an allegation would merely be an attempt to recast plaintiffs state law claims as violations of federal statutes (see Parker, 584 F Supp 2d at 1301 [an FDA finding that a class III device is “adulterated” within the meaning of 21 USC § 351 (h) is insufficient to support a parallel claim under the MDA]).

12008–2008
Montgomery v. Pena green
nyappdiv · 2005
1 sentence

2006This court acknowledges the existence of a series of cases from other departments which seem in very broad terms to indicate that evidence of degenerative changes in the spine is sufficient for a defendant on a threshold summary judgment motion to carry its burden on the motion (Cardillo v Xenakis, 31 AD3d 683 [2d Dept 2006]; Zarate v McDonald, 31 AD3d 632 [2d Dept 2006]; Gomez v Epstein, 29 AD3d 950 [2d Dept 2006]; Legendre v Bao, 29 AD3d 645 [2d Dept 2006]; Faulkner v Steinman, 28 AD3d 604 [2d Dept 2006]; Kaplan v Vanderhans, 26 AD3d 468 [2d Dept 2006]; Jimenez v Rojas, 26 AD3d 256 [1st Dept

12006–2006
Hernandez v. New York City Transit Authority green
nyappdiv · 2005
1 sentence

2006This court acknowledges the existence of a series of cases from other departments which seem in very broad terms to indicate that evidence of degenerative changes in the spine is sufficient for a defendant on a threshold summary judgment motion to carry its burden on the motion (Cardillo v Xenakis, 31 AD3d 683 [2d Dept 2006]; Zarate v McDonald, 31 AD3d 632 [2d Dept 2006]; Gomez v Epstein, 29 AD3d 950 [2d Dept 2006]; Legendre v Bao, 29 AD3d 645 [2d Dept 2006]; Faulkner v Steinman, 28 AD3d 604 [2d Dept 2006]; Kaplan v Vanderhans, 26 AD3d 468 [2d Dept 2006]; Jimenez v Rojas, 26 AD3d 256 [1st Dept

12006–2006
Giraldo v. Mandanici green
nyappdiv · 2005
1 sentence

2006This court acknowledges the existence of a series of cases from other departments which seem in very broad terms to indicate that evidence of degenerative changes in the spine is sufficient for a defendant on a threshold summary judgment motion to carry its burden on the motion (Cardillo v Xenakis, 31 AD3d 683 [2d Dept 2006]; Zarate v McDonald, 31 AD3d 632 [2d Dept 2006]; Gomez v Epstein, 29 AD3d 950 [2d Dept 2006]; Legendre v Bao, 29 AD3d 645 [2d Dept 2006]; Faulkner v Steinman, 28 AD3d 604 [2d Dept 2006]; Kaplan v Vanderhans, 26 AD3d 468 [2d Dept 2006]; Jimenez v Rojas, 26 AD3d 256 [1st Dept

12006–2006
Jimenez v. Rojas green
nyappdiv · 2006
1 sentence

2006This court acknowledges the existence of a series of cases from other departments which seem in very broad terms to indicate that evidence of degenerative changes in the spine is sufficient for a defendant on a threshold summary judgment motion to carry its burden on the motion (Cardillo v Xenakis, 31 AD3d 683 [2d Dept 2006]; Zarate v McDonald, 31 AD3d 632 [2d Dept 2006]; Gomez v Epstein, 29 AD3d 950 [2d Dept 2006]; Legendre v Bao, 29 AD3d 645 [2d Dept 2006]; Faulkner v Steinman, 28 AD3d 604 [2d Dept 2006]; Kaplan v Vanderhans, 26 AD3d 468 [2d Dept 2006]; Jimenez v Rojas, 26 AD3d 256 [1st Dept

12006–2006
Kaplan v. Vanderhans green
nyappdiv · 2006
1 sentence

2006This court acknowledges the existence of a series of cases from other departments which seem in very broad terms to indicate that evidence of degenerative changes in the spine is sufficient for a defendant on a threshold summary judgment motion to carry its burden on the motion (Cardillo v Xenakis, 31 AD3d 683 [2d Dept 2006]; Zarate v McDonald, 31 AD3d 632 [2d Dept 2006]; Gomez v Epstein, 29 AD3d 950 [2d Dept 2006]; Legendre v Bao, 29 AD3d 645 [2d Dept 2006]; Faulkner v Steinman, 28 AD3d 604 [2d Dept 2006]; Kaplan v Vanderhans, 26 AD3d 468 [2d Dept 2006]; Jimenez v Rojas, 26 AD3d 256 [1st Dept

12006–2006
Mullings v. Huntwork green
nyappdiv · 2006
1 sentence

2006This court acknowledges the existence of a series of cases from other departments which seem in very broad terms to indicate that evidence of degenerative changes in the spine is sufficient for a defendant on a threshold summary judgment motion to carry its burden on the motion (Cardillo v Xenakis, 31 AD3d 683 [2d Dept 2006]; Zarate v McDonald, 31 AD3d 632 [2d Dept 2006]; Gomez v Epstein, 29 AD3d 950 [2d Dept 2006]; Legendre v Bao, 29 AD3d 645 [2d Dept 2006]; Faulkner v Steinman, 28 AD3d 604 [2d Dept 2006]; Kaplan v Vanderhans, 26 AD3d 468 [2d Dept 2006]; Jimenez v Rojas, 26 AD3d 256 [1st Dept

12006–2006
Faulkner v. Steinman green
nyappdiv · 2006
1 sentence

2006This court acknowledges the existence of a series of cases from other departments which seem in very broad terms to indicate that evidence of degenerative changes in the spine is sufficient for a defendant on a threshold summary judgment motion to carry its burden on the motion (Cardillo v Xenakis, 31 AD3d 683 [2d Dept 2006]; Zarate v McDonald, 31 AD3d 632 [2d Dept 2006]; Gomez v Epstein, 29 AD3d 950 [2d Dept 2006]; Legendre v Bao, 29 AD3d 645 [2d Dept 2006]; Faulkner v Steinman, 28 AD3d 604 [2d Dept 2006]; Kaplan v Vanderhans, 26 AD3d 468 [2d Dept 2006]; Jimenez v Rojas, 26 AD3d 256 [1st Dept

12006–2006
Legendre v. Siqing Bao green
nyappdiv · 2006
1 sentence

2006This court acknowledges the existence of a series of cases from other departments which seem in very broad terms to indicate that evidence of degenerative changes in the spine is sufficient for a defendant on a threshold summary judgment motion to carry its burden on the motion (Cardillo v Xenakis, 31 AD3d 683 [2d Dept 2006]; Zarate v McDonald, 31 AD3d 632 [2d Dept 2006]; Gomez v Epstein, 29 AD3d 950 [2d Dept 2006]; Legendre v Bao, 29 AD3d 645 [2d Dept 2006]; Faulkner v Steinman, 28 AD3d 604 [2d Dept 2006]; Kaplan v Vanderhans, 26 AD3d 468 [2d Dept 2006]; Jimenez v Rojas, 26 AD3d 256 [1st Dept

12006–2006
Gomez v. Epstein green
nyappdiv · 2006
1 sentence

2006This court acknowledges the existence of a series of cases from other departments which seem in very broad terms to indicate that evidence of degenerative changes in the spine is sufficient for a defendant on a threshold summary judgment motion to carry its burden on the motion (Cardillo v Xenakis, 31 AD3d 683 [2d Dept 2006]; Zarate v McDonald, 31 AD3d 632 [2d Dept 2006]; Gomez v Epstein, 29 AD3d 950 [2d Dept 2006]; Legendre v Bao, 29 AD3d 645 [2d Dept 2006]; Faulkner v Steinman, 28 AD3d 604 [2d Dept 2006]; Kaplan v Vanderhans, 26 AD3d 468 [2d Dept 2006]; Jimenez v Rojas, 26 AD3d 256 [1st Dept

12006–2006
Zarate v. McDonald green
nyappdiv · 2006
1 sentence

2006This court acknowledges the existence of a series of cases from other departments which seem in very broad terms to indicate that evidence of degenerative changes in the spine is sufficient for a defendant on a threshold summary judgment motion to carry its burden on the motion (Cardillo v Xenakis, 31 AD3d 683 [2d Dept 2006]; Zarate v McDonald, 31 AD3d 632 [2d Dept 2006]; Gomez v Epstein, 29 AD3d 950 [2d Dept 2006]; Legendre v Bao, 29 AD3d 645 [2d Dept 2006]; Faulkner v Steinman, 28 AD3d 604 [2d Dept 2006]; Kaplan v Vanderhans, 26 AD3d 468 [2d Dept 2006]; Jimenez v Rojas, 26 AD3d 256 [1st Dept

12006–2006
Cardillo v. Xenakis green
nyappdiv · 2006
1 sentence

2006This court acknowledges the existence of a series of cases from other departments which seem in very broad terms to indicate that evidence of degenerative changes in the spine is sufficient for a defendant on a threshold summary judgment motion to carry its burden on the motion (Cardillo v Xenakis, 31 AD3d 683 [2d Dept 2006]; Zarate v McDonald, 31 AD3d 632 [2d Dept 2006]; Gomez v Epstein, 29 AD3d 950 [2d Dept 2006]; Legendre v Bao, 29 AD3d 645 [2d Dept 2006]; Faulkner v Steinman, 28 AD3d 604 [2d Dept 2006]; Kaplan v Vanderhans, 26 AD3d 468 [2d Dept 2006]; Jimenez v Rojas, 26 AD3d 256 [1st Dept

12006–2006
Pommells v. Perez green
ny · 2005
1 sentence

2006This is parallel to the rule that, in response to a defense motion for summary judgment, it is insufficient for a plaintiff to merely establish the existence of a disc herniation (Pommells, 4 NY3d at 574 ).

12006–2006
Zupan v. Firestone green
nyappdiv · 1982
11993–1993
Zupan v. Firestone green
ny · 1983
11993–1993
Walter v. Hoffman green
ny · 1935
11977–1977
McKinley v. . Hessen green
ny · 1911
11977–1977
Bright Radio Laboratories, Inc. v. Coastal Commercial Corp. green
nyappdiv · 1957
11977–1977
Bright Radio Laboratories, Inc. v. Coastal Commercial Corp. green
ny · 1958
11977–1977
Bakhshandeh v. American Cyanamid Co. green
ny · 1960
11977–1977
In Re Kauffman Mutual Fund Actions (Joseph B. Kauffman, Petitioner) green
scotus · 1973
11975–1975
Pomerantz v. Clark green
mad · 1951
11975–1975
Selzer v. Baker green
ny · 1946
11957–1957
Vose v. . Cockcroft green
ny · 1871
11957–1957
Claim of Dasaro v. Ford Motor Co. green
nyappdiv · 1952
11957–1957
Slote v. Cascade Holding Corp. green
ny · 1937
11956–1956
Nastasi v. State neutral
ny · 1949
11956–1956
Jasper v. . Rozinski neutral
ny · 1920
11956–1956
Newton v. . Hook green
ny · 1872
11956–1956
Nastasi v. State green
nyclaimsct · 1949
11956–1956
Post v. Lyford green
nyappdiv · 1954
11956–1956
Adamik v. Adamik green
nysupct · 1948
11956–1956
Arcuri v. Arcuri green
ny · 1934
11954–1954

Where else courts name it

CA 32 (1968–2025) TX 18 (1917–2024) MO 17 (1885–2020) UT 17 (1991–2020) NY 14 (1954–2025) MA 11 (1982–2025) WA 9 (2009–2023) AL 9 (1977–2017) IL 8 (1969–2021) MD 8 (1975–2022) WI 7 (1993–2011) TN 6 (1966–2013) CT 6 (1983–1998) PA 5 (1958–2019) MN 5 (2003–2015) AZ 5 (1962–2018) NJ 4 (1959–1996) IA 4 (2011–2017) WV 4 (2001–2023) OR 4 (1994–2024) RI 3 (2006–2023) CO 3 (1988–2025) MS 3 (2005–2015) ME 3 (1989–2024) KY 2 (2001–2012) MI 2 (2000–2014) ND 2 (2011–2011) NH 2 (1988–2011) FL 2 (1980–2002) DC 2 (1990–2013) OK 2 (1929–1929) SD 2 (1996–1997) LA 2 (2002–2024)

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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