signature requirement (New York) · Go Syfert
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signature requirement in New York

13 New York opinions name it 5 courts 1928–2025 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 (16)

CaseFollowedCited
Garris v. City of New Yorkgreen
nyappdiv · 2009 · cited in 1 New York opinions naming this issue, 2025–2025
1 sentence

2025To the extent that defendants meant to argue that there was no jurat accompanying the plaintiff’s signature on the hearing transcript, the hearing transcript can be used without the plaintiff’s signature because it was certified as accurate by the stenographer (see Garris v City of New York, 65 AD3d 953, 953 [1st Dept 2009]). 450521/2022 MELENDEZ, JASON L. vs.

11
Smith Barney Shearson Inc. v. Sacharowgreen
ny · 1997 · cited in 1 New York opinions naming this issue, 2022–2022
1 sentence

2022"Arbitration is favored in New York State as a means of resolving disputes, and courts should interfere as little as possible with agreements to arbitrate" ( Shah v Monpat Constr., Inc. , 65 AD3d 541, 543 ; see Matter of Smith Barney Shearson v Sacharow , 91 NY2d 39, 49-50 ).

11
Libertarian Party of Connecticut v. Lamontgreen
ca2 · 2020 · cited in 1 New York opinions naming this issue, 2021–2021
1 sentence

2021Because a "reasonably diligent candidate" could be expected to meet New York's requirements for independent candidates and gain a place on the ballot ( Libertarian Party of Connecticut , 977 F3d at 178 [internal quotation marks omitted]; see SAM Party of New York , 987 F3d at 276 ; see generally Munro v Socialist Workers Party , 479 US 189, 199 [1986]) and because those requirements do not unfairly discriminate against independent candidates ( see generally Burdick , 504 US at 434 ; Anderson , 460 US at 793-794 ), we conclude that Election Law § 6-158 (9) places only a minimal burden on the co

11
Johnny Swanson, III v. The State of Alabamagreen
ca11 · 2007 · cited in 1 New York opinions naming this issue, 2021–2021
1 sentence

2021That combination of rules for independent candidates in New York—a signature requirement substantially similar to that applicable to party candidates and a petition deadline that falls two months after the deadline for party candidates and one month prior to the primary election—is similar to election regulations in other states that have been found not to impose a severe burden on the constitutional rights of candidates and voters ( see Swanson v Worley , 490 F3d 894, 905-910 [11th Cir 2007]; Lawrence v Blackwell , 430 F3d 368, 373-374 [6th Cir 2005], cert denied 547 US 1178 [2006]; Wood v Me

11
Browne v. Baylessgreen
ariz · 2002 · cited in 1 New York opinions naming this issue, 2021–2021
1 sentence

2021That combination of rules for independent candidates in New York—a signature requirement substantially similar to that applicable to party candidates and a petition deadline that falls two months after the deadline for party candidates and one month prior to the primary election—is similar to election regulations in other states that have been found not to impose a severe burden on the constitutional rights of candidates and voters ( see Swanson v Worley , 490 F3d 894, 905-910 [11th Cir 2007]; Lawrence v Blackwell , 430 F3d 368, 373-374 [6th Cir 2005], cert denied 547 US 1178 [2006]; Wood v Me

11
Burdick v. Takushigreen
scotus · 1992 · cited in 1 New York opinions naming this issue, 2021–2021
1 sentence

2021Because a "reasonably diligent candidate" could be expected to meet New York's requirements for independent candidates and gain a place on the ballot ( Libertarian Party of Connecticut , 977 F3d at 178 [internal quotation marks omitted]; see SAM Party of New York , 987 F3d at 276 ; see generally Munro v Socialist Workers Party , 479 US 189, 199 [1986]) and because those requirements do not unfairly discriminate against independent candidates ( see generally Burdick , 504 US at 434 ; Anderson , 460 US at 793-794 ), we conclude that Election Law § 6-158 (9) places only a minimal burden on the co

11
SAM Party of N.Y. v. Kosinskigreen
ca2 · 2021 · cited in 1 New York opinions naming this issue, 2021–2021
1 sentence

2021Because a "reasonably diligent candidate" could be expected to meet New York's requirements for independent candidates and gain a place on the ballot ( Libertarian Party of Connecticut , 977 F3d at 178 [internal quotation marks omitted]; see SAM Party of New York , 987 F3d at 276 ; see generally Munro v Socialist Workers Party , 479 US 189, 199 [1986]) and because those requirements do not unfairly discriminate against independent candidates ( see generally Burdick , 504 US at 434 ; Anderson , 460 US at 793-794 ), we conclude that Election Law § 6-158 (9) places only a minimal burden on the co

11
Christopher Graveline v. Jocelyn Bensongreen
ca6 · 2021 · cited in 1 New York opinions naming this issue, 2021–2021
1 sentence

2021That combination of rules for independent candidates in New York—a signature requirement substantially similar to that applicable to party candidates and a petition deadline that falls two months after the deadline for party candidates and one month prior to the primary election—is similar to election regulations in other states that have been found not to impose a severe burden on the constitutional rights of candidates and voters ( see Swanson v Worley , 490 F3d 894, 905-910 [11th Cir 2007]; Lawrence v Blackwell , 430 F3d 368, 373-374 [6th Cir 2005], cert denied 547 US 1178 [2006]; Wood v Me

11
The Council Of Alternative Political Parties v. Lonna R. Hooksgreen
ca3 · 1999 · cited in 1 New York opinions naming this issue, 2021–2021
1 sentence

2021That combination of rules for independent candidates in New York—a signature requirement substantially similar to that applicable to party candidates and a petition deadline that falls two months after the deadline for party candidates and one month prior to the primary election—is similar to election regulations in other states that have been found not to impose a severe burden on the constitutional rights of candidates and voters ( see Swanson v Worley , 490 F3d 894, 905-910 [11th Cir 2007]; Lawrence v Blackwell , 430 F3d 368, 373-374 [6th Cir 2005], cert denied 547 US 1178 [2006]; Wood v Me

11
George R. (\Tex\") Wood v. Bruce Meadowsgreen
· 2000 · cited in 1 New York opinions naming this issue, 2021–2021
1 sentence

2021That combination of rules for independent candidates in New York—a signature requirement substantially similar to that applicable to party candidates and a petition deadline that falls two months after the deadline for party candidates and one month prior to the primary election—is similar to election regulations in other states that have been found not to impose a severe burden on the constitutional rights of candidates and voters ( see Swanson v Worley , 490 F3d 894, 905-910 [11th Cir 2007]; Lawrence v Blackwell , 430 F3d 368, 373-374 [6th Cir 2005], cert denied 547 US 1178 [2006]; Wood v Me

11
David Lawrence v. J. Kenneth Blackwell, Secretary, State of Ohiogreen
ca6 · 2005 · cited in 1 New York opinions naming this issue, 2021–2021
1 sentence

2021That combination of rules for independent candidates in New York—a signature requirement substantially similar to that applicable to party candidates and a petition deadline that falls two months after the deadline for party candidates and one month prior to the primary election—is similar to election regulations in other states that have been found not to impose a severe burden on the constitutional rights of candidates and voters ( see Swanson v Worley , 490 F3d 894, 905-910 [11th Cir 2007]; Lawrence v Blackwell , 430 F3d 368, 373-374 [6th Cir 2005], cert denied 547 US 1178 [2006]; Wood v Me

11
Munro v. Socialist Workers Partygreen
scotus · 1986 · cited in 1 New York opinions naming this issue, 2021–2021
1 sentence

2021Because a "reasonably diligent candidate" could be expected to meet New York's requirements for independent candidates and gain a place on the ballot ( Libertarian Party of Connecticut , 977 F3d at 178 [internal quotation marks omitted]; see SAM Party of New York , 987 F3d at 276 ; see generally Munro v Socialist Workers Party , 479 US 189, 199 [1986]) and because those requirements do not unfairly discriminate against independent candidates ( see generally Burdick , 504 US at 434 ; Anderson , 460 US at 793-794 ), we conclude that Election Law § 6-158 (9) places only a minimal burden on the co

11
Sokol v. Leadergreen
nyappdiv · 2010 · cited in 1 New York opinions naming this issue, 2011–2011
1 sentence

2011In considering a motion to dismiss a complaint pursuant to CPLR 3211 (a) (7), the court must “ ‘accept the facts as alleged in the complaint as true, accord plaintiffs the benefit of every possible favorable inference, and determine only whether the facts as alleged fit within any cognizable legal theory’ ” (Nonnon v City of New York, 9 NY3d 825, 827 [2007], quoting Leon v Martinez, 84 NY2d 83, 87-88 [1994]; see Sokol v Leader, 74 AD3d 1180, 1181 [2010]).

11
Nonnon v. City of New Yorkgreen
ny · 2007 · cited in 1 New York opinions naming this issue, 2011–2011
1 sentence

2011In considering a motion to dismiss a complaint pursuant to CPLR 3211 (a) (7), the court must “ ‘accept the facts as alleged in the complaint as true, accord plaintiffs the benefit of every possible favorable inference, and determine only whether the facts as alleged fit within any cognizable legal theory’ ” (Nonnon v City of New York, 9 NY3d 825, 827 [2007], quoting Leon v Martinez, 84 NY2d 83, 87-88 [1994]; see Sokol v Leader, 74 AD3d 1180, 1181 [2010]).

11
Leon v. Martinezgreen
ny · 1994 · cited in 1 New York opinions naming this issue, 2011–2011
1 sentence

2011In considering a motion to dismiss a complaint pursuant to CPLR 3211 (a) (7), the court must “ ‘accept the facts as alleged in the complaint as true, accord plaintiffs the benefit of every possible favorable inference, and determine only whether the facts as alleged fit within any cognizable legal theory’ ” (Nonnon v City of New York, 9 NY3d 825, 827 [2007], quoting Leon v Martinez, 84 NY2d 83, 87-88 [1994]; see Sokol v Leader, 74 AD3d 1180, 1181 [2010]).

11
Leising v. Multiple R Developmentgreen
nyappdiv · 1998 · cited in 1 New York opinions naming this issue, 2008–2008
1 sentence

2008Moreover, it does not contain the signature of the party to be charged, and the presence of Carriage Hill’s printed name at the top of the written statement, along with the name of the purchaser of the property, does not satisfy the signature requirement (compare Leising v Multiple R Dev., 249 AD2d 920, 920 [1998]).

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 (15)

CaseCitedYears
People v. Hill green
nyappdiv · 1988
2 sentences

1992The defendant acknowledged to the Grand Jury foreman that the signature on the waiver of immunity was in fact his own (see, e.g., People v Hodge, 141 AD2d 843 [2d Dept 1988]).

1988It is strict compliance if a defendant swears that the signature on the waiver of immunity is his own (People v Hodge, 141 AD2d 843 , supra; People v Rice, 93 Misc 2d 182 ).

21988–1992
Shah v. Monpat Construction, Inc. green
nyappdiv · 2009
1 sentence

2022"Arbitration is favored in New York State as a means of resolving disputes, and courts should interfere as little as possible with agreements to arbitrate" ( Shah v Monpat Constr., Inc. , 65 AD3d 541, 543 ; see Matter of Smith Barney Shearson v Sacharow , 91 NY2d 39, 49-50 ).

12022–2022
Aria v. United States, on Its Own Behalf and for the Benefit of the Fort Mojave Indian Tribe green
scotus · 2002
1 sentence

2021That combination of rules for independent candidates in New York—a signature requirement substantially similar to that applicable to party candidates and a petition deadline that falls two months after the deadline for party candidates and one month prior to the primary election—is similar to election regulations in other states that have been found not to impose a severe burden on the constitutional rights of candidates and voters ( see Swanson v Worley , 490 F3d 894, 905-910 [11th Cir 2007]; Lawrence v Blackwell , 430 F3d 368, 373-374 [6th Cir 2005], cert denied 547 US 1178 [2006]; Wood v Me

12021–2021
Anderson v. Celebrezze green
scotus · 1983
1 sentence

2021Because a "reasonably diligent candidate" could be expected to meet New York's requirements for independent candidates and gain a place on the ballot ( Libertarian Party of Connecticut , 977 F3d at 178 [internal quotation marks omitted]; see SAM Party of New York , 987 F3d at 276 ; see generally Munro v Socialist Workers Party , 479 US 189, 199 [1986]) and because those requirements do not unfairly discriminate against independent candidates ( see generally Burdick , 504 US at 434 ; Anderson , 460 US at 793-794 ), we conclude that Election Law § 6-158 (9) places only a minimal burden on the co

12021–2021
Stucchio Ex Rel. Hernandez v. Bikvan green
nyappdiv · 2017
1 sentence

2019In light of the expert affidavits submitted by both Signature and the plaintiff in Action No. 1, there are triable issues of fact as to whether Signature was negligent in knowingly permitting Anthony—a nonattorney—to be a signatory on the Baron escrow account, and as to whether any such negligence was a proximate [*3]cause of the loss of funds deposited in the Baron escrow account ( see generally Stucchio v Bikvan , 155 AD3d 666, 667 ).

12019–2019
Espinal v. Melville Snow Contractors, Inc. green
ny · 2002
1 sentence

2019Moreover, the Signature defendants demonstrated, prima facie, that they did not owe a duty of care to the plaintiff under the circumstances ( see generally Stiver v Good & Fair Carting & Moving, Inc. , 9 NY3d 253, 256-257 ; Church v Callanan Indus. , 99 NY2d 104 ; Espinal v Melville Snow Contrs. , 98 NY2d 136 ).

12019–2019
Church v. Callanan Industries, Inc. green
ny · 2002
1 sentence

2019Moreover, the Signature defendants demonstrated, prima facie, that they did not owe a duty of care to the plaintiff under the circumstances ( see generally Stiver v Good & Fair Carting & Moving, Inc. , 9 NY3d 253, 256-257 ; Church v Callanan Indus. , 99 NY2d 104 ; Espinal v Melville Snow Contrs. , 98 NY2d 136 ).

12019–2019
Stiver v. Good & Fair Carting & Moving, Inc. green
ny · 2007
1 sentence

2019Moreover, the Signature defendants demonstrated, prima facie, that they did not owe a duty of care to the plaintiff under the circumstances ( see generally Stiver v Good & Fair Carting & Moving, Inc. , 9 NY3d 253, 256-257 ; Church v Callanan Indus. , 99 NY2d 104 ; Espinal v Melville Snow Contrs. , 98 NY2d 136 ).

12019–2019
People v. Doe green
nysupct · 1991
1 sentence

2014(See People v Doe, 151 Misc 2d 829 [Sup Ct, Kings County 1991].) Defense efforts to strictly construe the signature requirement have failed where there was alternate evidence of authentication of grand jury action in the record.

12014–2014
People v. Stauber green
nyappdiv · 2003
1 sentence

2014As the Court noted in People v Stauber ( 307 AD2d 544 [3d Dept 2003]), over a century ago the Court of Appeals found the grand jurors’ appearance in court to present the indictment on the record sufficient to authenticate the indictment.

12014–2014
Pronti v. Hogan green
nyappdiv · 2000
1 sentence

2005In Pronti v Hogan ( 278 AD2d 841 [2000]), the Court held, in the absence of prejudice shown to the defendant, the lower court did not err in denying defendant’s motion to strike the summons and complaint based upon a violation of the signature requirement set forth in 22 NYCRR 130-1.la.

12005–2005
People v. Rupp green
nysupct · 1973
1 sentence

1989Moreover, in People v Rupp ( 75 Misc 2d 683, 686 ), the court held "[t]he signature of the District Attorney is no part of the indictment itself * * * [t]he signature is simply evidence that the District Attorney is prosecuting an offense in compliance with his statutory duty”.

11989–1989
People v. Gerald neutral
nycountyct · 1977
1 sentence

1988However, absent a swearing, the waiver is ineffective (People v Gerald, 91 Misc 2d 509 , supra).

11988–1988
People v. Rice neutral
nycountyct · 1978
1 sentence

1988It is strict compliance if a defendant swears that the signature on the waiver of immunity is his own (People v Hodge, 141 AD2d 843 , supra; People v Rice, 93 Misc 2d 182 ).

11988–1988
Critten v. Chemical National Bank green
ny · 1902
11928–1928

Where else courts name it

IL 38 (1941–2025) PA 36 (1982–2026) CA 27 (1969–2025) TX 25 (1948–2026) MO 22 (1982–2023) NY 13 (1928–2025) CT 13 (1983–2022) NC 11 (1940–2025) OH 11 (1991–2025) MD 11 (1914–2022) WA 11 (1973–2025) IN 10 (1913–2015) TN 10 (2000–2026) GA 9 (1907–2023) AL 9 (1985–2003) AZ 9 (1991–2022) AR 8 (1983–2016) MI 8 (1970–2023) ID 7 (1978–2023) CO 7 (2002–2025) MN 7 (1981–2016) IA 7 (1909–2025) KY 7 (1961–2026) WI 6 (1980–2020) UT 4 (2011–2024) OR 4 (1984–2023) VA 4 (2001–2023) MA 4 (1982–2024) AK 3 (1982–2021) LA 3 (1989–2024) SD 3 (2011–2026) NM 3 (1995–2012) WV 3 (1992–2019) FL 3 (1994–2009) OK 3 (1917–2000) NJ 2 (2003–2020) MT 2 (1984–2002) KS 2 (2003–2024) MS 2 (2017–2018) NE 2 (1995–1997)

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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