corollary rule (New York) · Go Syfert
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corollary rule in New York

87 New York opinions name it 10 courts 1911–2025 4 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 (37)

CaseFollowedCited
Barclay Knitwear Co. v. King'swear Enterprises Ltd.green
nyappdiv · 1988 · cited in 4 New York opinions naming this issue, 2014–2022
2 sentences

2022"Under New York law, in order to recover on its claim that the issuer wrongfully refused to honor its request to draw down on a letter of credit, the beneficiary must prove that it strictly complied with the terms of the letter of credit. 'The corollary to the rule of strict compliance is that the requirements in letters of credit must be explicit, and that all ambiguities are construed against the [issuer].' The reasoning is that '[s]ince the beneficiary must comply strictly with the requirements of the letter, it must know precisely and unequivocally what those requirements are'" ( BasicNet

2015“The corollary to the rule of strict *166 compliance is that the requirements in letters of credit must be explicit, and that all ambiguities are construed against the [issuer]” (Ma rino, 686 F2d at 115 [citation omitted]; see also Nissho Iwai Europe v Korea First Bank, 99 NY2d 115, 121-122 [2002]; Barclay Knitwear Co. v King’swear Enters., 141 AD2d 241, 246-247 [1st Dept 1988], lv denied 74 NY2d 605 [1989]).

44
Nissho Iwai Europe PLC v. Korea First Bankgreen
ny · 2002 · cited in 3 New York opinions naming this issue, 2014–2015
2 sentences

2015“The corollary to the rule of strict *166 compliance is that the requirements in letters of credit must be explicit, and that all ambiguities are construed against the [issuer]” (Ma rino, 686 F2d at 115 [citation omitted]; see also Nissho Iwai Europe v Korea First Bank, 99 NY2d 115, 121-122 [2002]; Barclay Knitwear Co. v King’swear Enters., 141 AD2d 241, 246-247 [1st Dept 1988], lv denied 74 NY2d 605 [1989]).

2014“The corollary to the rule of strict compliance is that the requirements in letters of credit must be explicit, and that all ambiguities are construed against the [issuer]” (Marino, 686 F2d at 115 [internal quotations marks and citation omitted]; see also Nissho Iwai Europe v Korea First Bank, 99 NY2d 115, 121-122 [2002]; Barclay Knitwear Co. v King’swear Enters., 141 AD2d 241, 246-247 [1st Dept 1988], lv denied 74 NY2d 605 [1989]).

33
O'Brien v. City of Syracusegreen
ny · 1981 · cited in 3 New York opinions naming this issue, 1989–1999
2 sentences

1999The proviso in CPLR 205 (a) that the toll is inapplicable when the prior action was dismissed on the merits is essentially a corollary of the principle of res judicata that “once a claim is brought to a final conclusion, all other claims arising out of the same transaction or series of transactions are barred, even if based upon different theories or if seeking a different remedy” (O’Brien v City of Syracuse, 54 NY2d 353, 357 [emphasis supplied]).

1999The proviso in CPLR 205 (a) that the toll is inapplicable when the prior action was dismissed on the merits is essentially a corollary of the principle of res judicata that "once a claim is brought to a final conclusion, all other claims arising out of the same transaction or series of transactions are barred, even if based upon different theories or if seeking a different remedy" ( O'Brien v City of Syracuse, 54 NY2d 353, 357 [emphasis supplied]).

23
Spenard v. Gregware General Contractinggreen
nyappdiv · 1998 · cited in 2 New York opinions naming this issue, 2000–2025
2 sentences

2025Contr. , 248 AD2d at 869 [internal quotation marks and citation omitted]), and "[w]hen the defendant presents some evidence that the device furnished was adequate and properly placed and that the conduct of the plaintiff may be the sole proximate cause of his or her injuries, partial summary judgment on the issue of liability will be denied because factual issues exist" ( Ball v Cascade Tissue Group.-N.Y., Inc. , 36 AD3d 1187, 1188 [3d Dept 2007]).

2000Contr., 248 AD2d 868, 869 [citations omitted]).

22
Giacona v. Marubeni Oceano (Panama) Corp.green
txsd · 1985 · cited in 2 New York opinions naming this issue, 2004–2004
2 sentences

2004Additionally, the rules of construction applicable to a tariff would bar such an attempt (Giacona v Marubeni Oceano [Panama] Corp., 623 F Supp 1560, 1569 [SD Tex 1985] [“a tariff should be construed strictly against the drafter of the tariff, as a corollary to the rule that written instruments will be construed strictly against their drafters”]).

2004Additionally, the rules of construction applicable to a tariff would bar such an attempt ( Giacona v Marubeni Oceano [ Panama ] Corp. , 623 F Supp 1560, 1569 [SD Tex 1985] ["a tariff should be construed strictly against the drafter of the tariff, as a corollary to the rule that written instruments will be construed strictly against their drafters"]).

22
Hecht v. City of New Yorkgreen
ny · 1983 · cited in 3 New York opinions naming this issue, 2018–2019
2 sentences

2019The corollary to this rule is that an appellate court's reversal or modification of a judgment as an appealing party will not inure to the benefit of a nonappealing co-party unless the judgment was rendered against parties having a united and inseverable interest in the judgment's subject matter, which itself permits no inconsistent application among the parties" ( id. at 61-62 [citations omitted]).

2019The corollary to this rule is that "an appellate court's scope of review with respect to an appellant, once an appeal has been timely taken, is generally limited to those parts of the judgment [or order] that have been appealed and that aggrieve the appealing party" ( Hecht v City of New York , 60 NY2d at 61 ).

13
Ball v. Cascade Tissue Group-New York, Inc.green
nyappdiv · 2007 · cited in 1 New York opinions naming this issue, 2025–2025
1 sentence

2025Contr. , 248 AD2d at 869 [internal quotation marks and citation omitted]), and "[w]hen the defendant presents some evidence that the device furnished was adequate and properly placed and that the conduct of the plaintiff may be the sole proximate cause of his or her injuries, partial summary judgment on the issue of liability will be denied because factual issues exist" ( Ball v Cascade Tissue Group.-N.Y., Inc. , 36 AD3d 1187, 1188 [3d Dept 2007]).

11
BasicNet S.P.A. v. CFP Services Ltd.green
nyappdiv · 2015 · cited in 1 New York opinions naming this issue, 2022–2022
1 sentence

2022"Under New York law, in order to recover on its claim that the issuer wrongfully refused to honor its request to draw down on a letter of credit, the beneficiary must prove that it strictly complied with the terms of the letter of credit. 'The corollary to the rule of strict compliance is that the requirements in letters of credit must be explicit, and that all ambiguities are construed against the [issuer].' The reasoning is that '[s]ince the beneficiary must comply strictly with the requirements of the letter, it must know precisely and unequivocally what those requirements are'" ( BasicNet

11
People Ex Rel. Hilton v. Fahrenkopfgreen
ny · 1938 · cited in 1 New York opinions naming this issue, 2016–2016
2 sentences

2016Hilton v Fahrenkopf, 279 NY 49, 52-53 [1938] [“Each annual proceeding is separate and distinct from, every other”]; see also Vantage Petroleum,; Bay Isle Oil Co. v Board of Assessment Review of Town of Babylon, 61 NY2d 695, 698 [1984]), and this is a factor that supports my conclusion that each and every assessment must be challenged individually. 5 More fundamentally, however, the requirement implicit in article 7 that a taxpayer challenge the assessment for each year in which a refund is sought is primarily a corollary of the principle that taxes paid without protest — as were petitioner’s p

2016Hilton v Fahrenkopf, 279 NY 49, 52-53 [1938] ["Each annual proceeding is separate and distinct from every other"]; see also Vantage Petroleum Bay Isle Oil Co. v Board of Assessment Review of Town of Babylon, 61 NY2d 695, 698 [1984]), and this is a factor that supports my conclusion that each and every assessment must be challenged individually.5 More fundamentally, however, the requirement implicit in article 7 that a taxpayer challenge the assessment for each year in which a refund is sought is primarily a corollary of the principle that taxes paid without protest -- as were petitioner's prop

11
Adrico Realty Corp. v. City of New Yorkgreen
ny · 1928 · cited in 1 New York opinions naming this issue, 2016–2016
2 sentences

2016Importing Corp. v City of New York, 3 NY2d 418, 425 [1957]; Adrico Realty Corp. v City of New York, 250 NY 29, 32 [1928]).

2016Importing Corp. v City of New York, 3 NY2d 418, 425 [1957]; Adrico Realty Corp. v City of New York, 250 NY 29, 32 [1928]).

11
Vantage Petroleum, Bay Isle Oil Co., Inc. v. Bd. of Assessment Review of the Town of Babylongreen
ny · 1984 · cited in 1 New York opinions naming this issue, 2016–2016
11
Mercury Machine Importing Corp. v. City of New Yorkgreen
ny · 1957 · cited in 1 New York opinions naming this issue, 2016–2016
2 sentences

2016Importing Corp. v City of New York, 3 NY2d 418, 425 [1957]; Adrico Realty Corp. v City of New York, 250 NY 29, 32 [1928]).

2016Importing Corp. v City of New York, 3 NY2d 418, 425 [1957]; Adrico Realty Corp. v City of New York, 250 NY 29, 32 [1928]).

11
Video Aid Corp. v. Town of Wallkillgreen
ny · 1995 · cited in 1 New York opinions naming this issue, 2016–2016
2 sentences

2016Hilton v Fahrenkopf, 279 NY 49, 52-53 [1938] [“Each annual proceeding is separate and distinct from, every other”]; see also Vantage Petroleum,; Bay Isle Oil Co. v Board of Assessment Review of Town of Babylon, 61 NY2d 695, 698 [1984]), and this is a factor that supports my conclusion that each and every assessment must be challenged individually. 5 More fundamentally, however, the requirement implicit in article 7 that a taxpayer challenge the assessment for each year in which a refund is sought is primarily a corollary of the principle that taxes paid without protest — as were petitioner’s p

2016Hilton v Fahrenkopf, 279 NY 49, 52-53 [1938] ["Each annual proceeding is separate and distinct from every other"]; see also Vantage Petroleum Bay Isle Oil Co. v Board of Assessment Review of Town of Babylon, 61 NY2d 695, 698 [1984]), and this is a factor that supports my conclusion that each and every assessment must be challenged individually.5 More fundamentally, however, the requirement implicit in article 7 that a taxpayer challenge the assessment for each year in which a refund is sought is primarily a corollary of the principle that taxes paid without protest -- as were petitioner's prop

11
City of Rochester v. Chiarellagreen
ny · 1983 · cited in 1 New York opinions naming this issue, 2016–2016
2 sentences

2016Hilton v Fahrenkopf, 279 NY 49, 52-53 [1938] [“Each annual proceeding is separate and distinct from, every other”]; see also Vantage Petroleum,; Bay Isle Oil Co. v Board of Assessment Review of Town of Babylon, 61 NY2d 695, 698 [1984]), and this is a factor that supports my conclusion that each and every assessment must be challenged individually. 5 More fundamentally, however, the requirement implicit in article 7 that a taxpayer challenge the assessment for each year in which a refund is sought is primarily a corollary of the principle that taxes paid without protest — as were petitioner’s p

2016Hilton v Fahrenkopf, 279 NY 49, 52-53 [1938] ["Each annual proceeding is separate and distinct from every other"]; see also Vantage Petroleum Bay Isle Oil Co. v Board of Assessment Review of Town of Babylon, 61 NY2d 695, 698 [1984]), and this is a factor that supports my conclusion that each and every assessment must be challenged individually.5 More fundamentally, however, the requirement implicit in article 7 that a taxpayer challenge the assessment for each year in which a refund is sought is primarily a corollary of the principle that taxes paid without protest -- as were petitioner's prop

11
Andrews v. New York City Housing Authoritygreen
nyappdiv · 2011 · cited in 1 New York opinions naming this issue, 2014–2014
11
Abrams v. Berelsongreen
nyappdiv · 2012 · cited in 1 New York opinions naming this issue, 2014–2014
11
Specialized Realty Services, LLC v. Town of Tuxedogreen
nyappdiv · 2013 · cited in 1 New York opinions naming this issue, 2014–2014
11
Levitt v. County of Suffolkgreen
nyappdiv · 1990 · cited in 1 New York opinions naming this issue, 2014–2014
11
Davi v. Occhinogreen
nyappdiv · 2014 · cited in 1 New York opinions naming this issue, 2014–2014
11
Board of Supervisors v. Aulisigreen
nyappdiv · 1978 · cited in 1 New York opinions naming this issue, 2011–2011
11
In re Dylan C.green
nyappdiv · 2009 · cited in 1 New York opinions naming this issue, 2010–2010
11
Parker v. Blauvelt Volunteer Fire Co.green
ny · 1999 · cited in 1 New York opinions naming this issue, 2007–2007
11
Brown v. Gerdesgreen
scotus · 1944 · cited in 1 New York opinions naming this issue, 2007–2007
11
Xiao Yang Chen v. Fischergreen
ny · 2005 · cited in 1 New York opinions naming this issue, 2007–2007
11
Broz v. Cellular Information Systems, Inc.green
del · 1996 · cited in 1 New York opinions naming this issue, 2007–2007
11
Fink v. . Finkgreen
· 1902 · cited in 1 New York opinions naming this issue, 2006–2006
11
In re the Estate of Ziolkowskigreen
nysurct · 1965 · cited in 1 New York opinions naming this issue, 2006–2006
11
In re the Estate of Jaccomagreen
nyappdiv · 1988 · cited in 1 New York opinions naming this issue, 2006–2006
11
Arbutina v. Bahuleyangreen
nyappdiv · 1980 · cited in 1 New York opinions naming this issue, 2002–2002
11
Matter of Steyergreen
ny · 1988 · cited in 1 New York opinions naming this issue, 2002–2002
11
Miller v. Continental Insurancegreen
ny · 1976 · cited in 1 New York opinions naming this issue, 2002–2002
11
United States v. Gregory Sackingergreen
ca2 · 1983 · cited in 1 New York opinions naming this issue, 2001–2001
11
Pinaud v. Jamesgreen
ca2 · 1988 · cited in 1 New York opinions naming this issue, 2001–2001
11
Anthony Del Guzzi v. United States of America U.S. Parole Commission United States Marshal U.S. Attorney Generalgreen
ca9 · 1992 · cited in 1 New York opinions naming this issue, 2001–2001
11
International Society for Krishna Consciousness, Inc. v. Leegreen
scotus · 1992 · cited in 1 New York opinions naming this issue, 1997–1997
11
People v. Banchgreen
ny · 1992 · cited in 1 New York opinions naming this issue, 1994–1994
11
People v. Novoagreen
ny · 1987 · cited in 1 New York opinions naming this issue, 1994–1994
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 (43)

CaseCitedYears
Ryan v. New York Telephone Co. green
ny · 1984
2 sentences

1999Co., 62 NY2d 494, 500 ).

1997Co., 62 NY2d 494, 500 ).

41995–1999
Wilson Sullivan Co. v. International Paper Makers Realty Corp. green
ny · 1954
2 sentences

2022However, the corollary to that rule is that if, in exercising its power to revoke the agency, the principal has violated its contractual obligations, "it must respond to [the agent] in damages" ( Wilson Sullivan , 307 NY at 24-25 ).

2022However, the corollary to that rule is that if, in exercising its power to revoke the agency, the principal has violated its contractual obligations, "it must respond to [the agent] in damages" ( Wilson Sullivan , 307 NY at 24-25 ).

22022–2022
People v. Fratello green
ny · 1998
2 sentences

2014However, a corollary of this rule applies “when the jury, acting within its rightful province of determining credibility, weighing evidence and drawing justifiable inferences from proven facts, has an objective, rational basis for resolving beyond a reasonable doubt the contradictory inculpating and exculpating versions of the events given by the witness” (People v Fratello, 92 NY2d at 573-574 ).

2014However, a corollary of this rule applies “when the jury, acting within its rightful province of determining credibility, weighing evidence and drawing justifiable inferences from proven facts, has an objective, rational basis for resolving beyond a reasonable doubt the contradictory inculpating and exculpating versions of the events given by the witness” (People v Fratello, 92 NY2d at 573-574 ).

22014–2014
Hogan v. Metropolitan Street Railway Co. neutral
nyappdiv · 1902
2 sentences

2010John v Andrews Inst, for Girls, 192 NY 382, 386-389 , supra; Bonat v Crosswell, 241 App Div 230 ; Kohlmetz v Amdoursky, 227 App Div 758 ; San Lucas v Bornn & Co., 173 App Div 703 ; Orr v Wolff, 71 App Div 614 ) unless the judgment was rendered against parties having a united and inseverable interest in the judgment’s subject matter, which itself permits no inconsistent application among the parties (see Matter of Win-burn, 270 NY 196, 198 ; United States Print. & Lithograph Co. v Powers, 233 NY 143, 152-155 ).” Again, the plaintiffs here did not take an appeal.

1983John v Andrews Inst. for Girls, 192 NY 382, 386-389 , supra; Bonat v Crosswell, 241 App Div 230 ; Kohlmetz v Amdoursky, 227 App Div 758 ; San Lucas v Bornn & Co., 173 App Div 703 ; Orr v Wolff, 71 App Div 614 ) unless the judgment was rendered against parties having a united and inseverable interest in the judgment’s subject matter, which itself permits no inconsistent application among the parties (see Matter of Winburn, 270 NY 196, 198 ; United States Print. & Lithograph Co. v Powers, 233 NY 143,152-155 ).

21983–2010
In Re the Will of Winburn green
ny · 1936
2 sentences

2010John v Andrews Inst, for Girls, 192 NY 382, 386-389 , supra; Bonat v Crosswell, 241 App Div 230 ; Kohlmetz v Amdoursky, 227 App Div 758 ; San Lucas v Bornn & Co., 173 App Div 703 ; Orr v Wolff, 71 App Div 614 ) unless the judgment was rendered against parties having a united and inseverable interest in the judgment’s subject matter, which itself permits no inconsistent application among the parties (see Matter of Win-burn, 270 NY 196, 198 ; United States Print. & Lithograph Co. v Powers, 233 NY 143, 152-155 ).” Again, the plaintiffs here did not take an appeal.

1983John v Andrews Inst. for Girls, 192 NY 382, 386-389 , supra; Bonat v Crosswell, 241 App Div 230 ; Kohlmetz v Amdoursky, 227 App Div 758 ; San Lucas v Bornn & Co., 173 App Div 703 ; Orr v Wolff, 71 App Div 614 ) unless the judgment was rendered against parties having a united and inseverable interest in the judgment’s subject matter, which itself permits no inconsistent application among the parties (see Matter of Winburn, 270 NY 196, 198 ; United States Print. & Lithograph Co. v Powers, 233 NY 143,152-155 ).

21983–2010
John v. Andrews Institute for Girls green
ny · 1908
2 sentences

2010John v Andrews Inst, for Girls, 192 NY 382, 386-389 , supra; Bonat v Crosswell, 241 App Div 230 ; Kohlmetz v Amdoursky, 227 App Div 758 ; San Lucas v Bornn & Co., 173 App Div 703 ; Orr v Wolff, 71 App Div 614 ) unless the judgment was rendered against parties having a united and inseverable interest in the judgment’s subject matter, which itself permits no inconsistent application among the parties (see Matter of Win-burn, 270 NY 196, 198 ; United States Print. & Lithograph Co. v Powers, 233 NY 143, 152-155 ).” Again, the plaintiffs here did not take an appeal.

1983John v Andrews Inst. for Girls, 192 NY 382, 386-389 , supra; Bonat v Crosswell, 241 App Div 230 ; Kohlmetz v Amdoursky, 227 App Div 758 ; San Lucas v Bornn & Co., 173 App Div 703 ; Orr v Wolff, 71 App Div 614 ) unless the judgment was rendered against parties having a united and inseverable interest in the judgment’s subject matter, which itself permits no inconsistent application among the parties (see Matter of Winburn, 270 NY 196, 198 ; United States Print. & Lithograph Co. v Powers, 233 NY 143,152-155 ).

21983–2010
United States Printing & Lithograph Co. v. Powers green
ny · 1922
2 sentences

2010John v Andrews Inst, for Girls, 192 NY 382, 386-389 , supra; Bonat v Crosswell, 241 App Div 230 ; Kohlmetz v Amdoursky, 227 App Div 758 ; San Lucas v Bornn & Co., 173 App Div 703 ; Orr v Wolff, 71 App Div 614 ) unless the judgment was rendered against parties having a united and inseverable interest in the judgment’s subject matter, which itself permits no inconsistent application among the parties (see Matter of Win-burn, 270 NY 196, 198 ; United States Print. & Lithograph Co. v Powers, 233 NY 143, 152-155 ).” Again, the plaintiffs here did not take an appeal.

1983John v Andrews Inst. for Girls, 192 NY 382, 386-389 , supra; Bonat v Crosswell, 241 App Div 230 ; Kohlmetz v Amdoursky, 227 App Div 758 ; San Lucas v Bornn & Co., 173 App Div 703 ; Orr v Wolff, 71 App Div 614 ) unless the judgment was rendered against parties having a united and inseverable interest in the judgment’s subject matter, which itself permits no inconsistent application among the parties (see Matter of Winburn, 270 NY 196, 198 ; United States Print. & Lithograph Co. v Powers, 233 NY 143,152-155 ).

21983–2010
San Lucas v. Bornn & Co. neutral
nyappdiv · 1916
2 sentences

2010John v Andrews Inst, for Girls, 192 NY 382, 386-389 , supra; Bonat v Crosswell, 241 App Div 230 ; Kohlmetz v Amdoursky, 227 App Div 758 ; San Lucas v Bornn & Co., 173 App Div 703 ; Orr v Wolff, 71 App Div 614 ) unless the judgment was rendered against parties having a united and inseverable interest in the judgment’s subject matter, which itself permits no inconsistent application among the parties (see Matter of Win-burn, 270 NY 196, 198 ; United States Print. & Lithograph Co. v Powers, 233 NY 143, 152-155 ).” Again, the plaintiffs here did not take an appeal.

1983John v Andrews Inst. for Girls, 192 NY 382, 386-389 , supra; Bonat v Crosswell, 241 App Div 230 ; Kohlmetz v Amdoursky, 227 App Div 758 ; San Lucas v Bornn & Co., 173 App Div 703 ; Orr v Wolff, 71 App Div 614 ) unless the judgment was rendered against parties having a united and inseverable interest in the judgment’s subject matter, which itself permits no inconsistent application among the parties (see Matter of Winburn, 270 NY 196, 198 ; United States Print. & Lithograph Co. v Powers, 233 NY 143,152-155 ).

21983–2010
Kohlmetz v. Amdoursky neutral
nyappdiv · 1929
2 sentences

2010John v Andrews Inst, for Girls, 192 NY 382, 386-389 , supra; Bonat v Crosswell, 241 App Div 230 ; Kohlmetz v Amdoursky, 227 App Div 758 ; San Lucas v Bornn & Co., 173 App Div 703 ; Orr v Wolff, 71 App Div 614 ) unless the judgment was rendered against parties having a united and inseverable interest in the judgment’s subject matter, which itself permits no inconsistent application among the parties (see Matter of Win-burn, 270 NY 196, 198 ; United States Print. & Lithograph Co. v Powers, 233 NY 143, 152-155 ).” Again, the plaintiffs here did not take an appeal.

1983John v Andrews Inst. for Girls, 192 NY 382, 386-389 , supra; Bonat v Crosswell, 241 App Div 230 ; Kohlmetz v Amdoursky, 227 App Div 758 ; San Lucas v Bornn & Co., 173 App Div 703 ; Orr v Wolff, 71 App Div 614 ) unless the judgment was rendered against parties having a united and inseverable interest in the judgment’s subject matter, which itself permits no inconsistent application among the parties (see Matter of Winburn, 270 NY 196, 198 ; United States Print. & Lithograph Co. v Powers, 233 NY 143,152-155 ).

21983–2010
Bonat v. Crosswell neutral
nyappdiv · 1934
2 sentences

2010John v Andrews Inst, for Girls, 192 NY 382, 386-389 , supra; Bonat v Crosswell, 241 App Div 230 ; Kohlmetz v Amdoursky, 227 App Div 758 ; San Lucas v Bornn & Co., 173 App Div 703 ; Orr v Wolff, 71 App Div 614 ) unless the judgment was rendered against parties having a united and inseverable interest in the judgment’s subject matter, which itself permits no inconsistent application among the parties (see Matter of Win-burn, 270 NY 196, 198 ; United States Print. & Lithograph Co. v Powers, 233 NY 143, 152-155 ).” Again, the plaintiffs here did not take an appeal.

1983John v Andrews Inst. for Girls, 192 NY 382, 386-389 , supra; Bonat v Crosswell, 241 App Div 230 ; Kohlmetz v Amdoursky, 227 App Div 758 ; San Lucas v Bornn & Co., 173 App Div 703 ; Orr v Wolff, 71 App Div 614 ) unless the judgment was rendered against parties having a united and inseverable interest in the judgment’s subject matter, which itself permits no inconsistent application among the parties (see Matter of Winburn, 270 NY 196, 198 ; United States Print. & Lithograph Co. v Powers, 233 NY 143,152-155 ).

21983–2010
Beekman Hill Ass'n v. Chin green
nyappdiv · 2000
2 sentences

2005(See Matter of Beekman Hill Assn. v Chin, 274 AD2d 161 [1st Dept 2000]; McKinney’s Cons Laws of NY, Book 1, Statutes §§ 97, 98.) A corollary rule is that all parts of a statute are to be harmonized with each other as well as with the general intent of the whole statute.

2005(See Matter of Beekman Hill Assn, v Chin, 274 AD2d 161 [1st Dept 2000]; McKinney’s Cons Laws of NY, Book 1, Statutes §§ 97, 98.) A corollary rule is that all parts of a statute are to be harmonized with each other as well as with the general intent of the whole statute.

22005–2005
Vincent v. Thompson green
nyappdiv · 1975
2 sentences

1983Collateral estoppel is a corollary to the doctrine of res judicata; it permits in certain situations the determination of an issue of fact or law raised in a subsequent action by reference to a previous judgment on a different cause of action in which the same issue was necessarily raised and decided (Statter v Statter, 2 NY2d 668 ; Siegel, New York Practice, § 464, p 614; 9 Carmody-Wait 2d, NY Prac, § 63:204, pp 208-209; cf. Ashe v Swenson, 397 US 436, 443 ).” As was written in Vincent v Thompson ( 50 AD2d 211, 217 ): “When collateral estoppel operates, certain questions actually litigated an

1976Inherent in the concept of collateral estoppel is the fairness of the process, to the end that a party should not be precluded from obtaining a full and fair hearing in a forum on his claim (cf. Read v Sacco, 49 AD2d 471, 474 ; Vincent v Thompson, 50 AD2d 211, 218 ).

21976–1983
Ashe v. Swenson green
scotus · 1970
2 sentences

1983Collateral estoppel is a corollary to the doctrine of res judicata; it permits in certain situations the determination of an issue of fact or law raised in a subsequent action by reference to a previous judgment on a different cause of action in which the same issue was necessarily raised and decided (Statter v Statter, 2 NY2d 668 ; Siegel, New York Practice, § 464, p 614; 9 Carmody-Wait 2d, NY Prac, § 63:204, pp 208-209; cf. Ashe v Swenson, 397 US 436, 443 ).” As was written in Vincent v Thompson ( 50 AD2d 211, 217 ): “When collateral estoppel operates, certain questions actually litigated an

1979Collateral estoppel is a corollary to the doctrine of res judicata; it permits in certain situations the determination of an issue of fact or law raised in a subsequent action by reference to a previous judgment on a different cause of action in which the same issue was necessarily raised and decided (Statter v Statter, 2 NY2d 668 ; Siegel, New York Practice, § 464, p 614; 9 Carmody-Wait 2d, NY Prac, § 63:204, pp 208-209; cf. Ashe v Swenson, 397 US 436, 443 ).

21979–1983
Statter v. Statter green
ny · 1957
2 sentences

1983Collateral estoppel is a corollary to the doctrine of res judicata; it permits in certain situations the determination of an issue of fact or law raised in a subsequent action by reference to a previous judgment on a different cause of action in which the same issue was necessarily raised and decided (Statter v Statter, 2 NY2d 668 ; Siegel, New York Practice, § 464, p 614; 9 Carmody-Wait 2d, NY Prac, § 63:204, pp 208-209; cf. Ashe v Swenson, 397 US 436, 443 ).” As was written in Vincent v Thompson ( 50 AD2d 211, 217 ): “When collateral estoppel operates, certain questions actually litigated an

1979Collateral estoppel is a corollary to the doctrine of res judicata; it permits in certain situations the determination of an issue of fact or law raised in a subsequent action by reference to a previous judgment on a different cause of action in which the same issue was necessarily raised and decided (Statter v Statter, 2 NY2d 668 ; Siegel, New York Practice, § 464, p 614; 9 Carmody-Wait 2d, NY Prac, § 63:204, pp 208-209; cf. Ashe v Swenson, 397 US 436, 443 ).

21979–1983
People v. Ferraro green
ny · 1944
2 sentences

1961It has been said that “ The right of a cross-examiner to use a witness ’ own prior statement in which he has given a contrary version of the purpose of testimonial impeachment and the corollary rule that such prior statements have no substantial or independent testimonial value are so firmly imbedded in our law of evidence that the citation of authority is scarcely required. (3 Wigmore on Evidence [3d ed.], § 1018; Matter of Roge v. Valentine, 280 N. Y. 268, 277 ; People v. Ferraro, 293 N. Y. 51, 56 ; 30 Corn.

1956The right of a cross-examiner to use a witness’ own prior statement in which he has given a contrary version for the purpose of testimonial impeachment and the corollary rule that such prior statements have no substantial or independent testimonial value are so firmly imbedded in our law of eAddence that the citation of authority is scarcely required. (3 Wigmore on Evidence [3d ed.], § 1018; Matter of Roge v. Valentine, 280 N. Y. 268, 277 ; People v. Ferraro, 293 N. Y. 51, 56 ; 30 Corn.

21956–1961
Matter of Roge v. Valentine green
ny · 1939
2 sentences

1961It has been said that “ The right of a cross-examiner to use a witness ’ own prior statement in which he has given a contrary version of the purpose of testimonial impeachment and the corollary rule that such prior statements have no substantial or independent testimonial value are so firmly imbedded in our law of evidence that the citation of authority is scarcely required. (3 Wigmore on Evidence [3d ed.], § 1018; Matter of Roge v. Valentine, 280 N. Y. 268, 277 ; People v. Ferraro, 293 N. Y. 51, 56 ; 30 Corn.

1956The right of a cross-examiner to use a witness’ own prior statement in which he has given a contrary version for the purpose of testimonial impeachment and the corollary rule that such prior statements have no substantial or independent testimonial value are so firmly imbedded in our law of eAddence that the citation of authority is scarcely required. (3 Wigmore on Evidence [3d ed.], § 1018; Matter of Roge v. Valentine, 280 N. Y. 268, 277 ; People v. Ferraro, 293 N. Y. 51, 56 ; 30 Corn.

21956–1961
Kenyon v. Farris neutral
· 1880
2 sentences

1924The leading case to that effect in this country is Kenyon v. Farris ( 47 Conn. 510 ), in which the earlier English decisions are reviewed.

1911The leading case to that effect in this country is Kenyon v. Farris ( 47 Conn. 510 ), in which the earlier English decisions are reviewed.

21911–1924
Derby v. Bitan green
nyappdiv · 2013
12014–2014
Rosenfeld v. A. H. Robins Co. green
ny · 1978
12011–2011
Schumer v. Holtzman green
ny · 1983
12011–2011
Toman v. East River Management Corp. neutral
nyappdiv · 1983
12010–2010
Friedman-Kien v. City of New York neutral
ny · 1984
12010–2010
Howlett Ex Rel. Howlett v. Rose green
scotus · 1990
12007–2007
National Private Truck Council, Inc. v. Oklahoma Tax Comm'n green
scotus · 1995
12007–2007
Pauk v. BD. OF TRS. OF THE CITY UNIV. OF NEW YORK green
nyappdiv · 1985
12007–2007
Pauk v. Board of Trustees green
ny · 1986
12007–2007
Pruchnowski v. Prudential Insurance neutral
ny · 1936
12006–2006
Curtis v. Silvorili neutral
nyappdiv · 1934
12006–2006
General Stencils, Inc. v. Chiappa green
ny · 1966
12002–2002
People v. Flores green
ny · 1994
12000–2000
People v. Kemp green
ny · 1999
12000–2000
H. R. Moch Co. v. Rensselaer Water Co. green
ny · 1928
12000–2000
People v. Baldi green
ny · 1981
12000–2000
In re Whitehead green
nysupct · 1996
11998–1998
Quinlan v. Eastern Refractories Co. green
nyappdiv · 1995
11998–1998
Sengstack v. Sengstack green
ny · 1958
11998–1998
United States Postal Service v. Council of Greenburgh Civic Associations green
scotus · 1981
11997–1997
Perry Education Ass'n v. Perry Local Educators' Ass'n green
scotus · 1983
11997–1997
Kush v. City of Buffalo green
ny · 1983
11991–1991
Kriz v. Schum green
ny · 1989
11991–1991

Statutes the citing opinions construe

NY § N.Y. Labor Law § 240 (3) NY § N.Y. Penal Law § 265.03 (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

TX 409 (1913–2026) CA 280 (1900–2026) IL 103 (1873–2023) NY 87 (1911–2025) PA 86 (1915–2024) NJ 77 (1896–2026) MD 69 (1928–2023) WA 66 (1922–2026) MO 65 (1905–2025) GA 57 (1912–2023) FL 49 (1938–2023) AL 44 (1909–2015) OH 39 (1932–2026) MI 37 (1940–2023) CT 37 (1937–2025) LA 35 (1919–2024) IN 34 (1918–2019) IA 32 (1917–2023) MS 32 (1876–2022) WI 32 (1965–2024) KS 27 (1875–2026) OR 26 (1897–2026) TN 26 (1904–2025) KY 25 (1922–2024) WV 24 (1901–2023) VA 23 (1963–2024) WY 23 (1968–2022) SC 20 (1907–2020) CO 19 (1912–2021) DE 19 (1945–2026) VT 17 (1913–2025) MT 16 (1898–2012) NC 15 (1921–2018) AZ 15 (1956–2018) MA 14 (1951–2024) NM 14 (1914–2014) RI 14 (1968–2018) OK 13 (1925–2014) ME 12 (1922–2020) NE 12 (1959–2023) MN 12 (1954–2025) ID 11 (1977–2021) DC 11 (1976–2025) UT 11 (1979–2026) AR 11 (1927–2017) ND 7 (1895–2015) NV 6 (1983–2015) NH 3 (1997–2021) SD 3 (1998–2003) HI 2 (1944–2015) AK 2 (1993–2023)

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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