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12 New York opinions name it 3 courts 2004–2025 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.
| Case | Followed | Cited |
|---|---|---|
Catherine G. v. County of Essexgreen2 sentences2025As respondents correctly note, "[l]eave is not appropriate for a patently meritless claim" ( Matter of Catherine G. v County of Essex , 3 NY3d 175, 179 [2004]), and schools are not generally "held liable for injuries that occur off school property and beyond the orbit of [their] authority" ( Donofrio v Rockville Ctr. 2025“Leave is not appropriate for a patently meritless claim” (Matter of Catherine G. v County of Essex, 3 NY3d 175, 179 [2004]; Swinton v City of New York, 61 AD3d 557, 558 [1st Dept 2009]). | 10 | 10 |
Dischiavi v. Calligreen2 sentences2015Respondents are correct that the claim is barred by section 207-c (see Damiani v City of Buffalo, 198 AD2d 814 , 814-815 [1993], lv denied 83 NY2d 757 [1994]; see also Dischiavi v Calli, 111 AD3d 1258, 1262 [2013]), and leave to file a late notice of claim “is not appropriate for a patently meritless claim” (Matter of Catherine G. v County of Essex, 3 NY3d 175, 179 [2004]). 2015Respondents are correct that the claim is barred by section 207-c (see Damiani v City of Buffalo, 198 AD2d 814 , 814-815 [1993], lv denied 83 NY2d 757 [1994]; see also Dischiavi v Calli, 111 AD3d 1258, 1262 [2013]), and leave to file a late notice of claim “is not appropriate for a patently meritless claim” (Matter of Catherine G. v County of Essex, 3 NY3d 175, 179 [2004]). | 3 | 3 |
Swain v. County of Albanygreen2 sentences2007School Dist., 29 AD3d 1230, 1231 [2006], appeal dismissed 7 NY3d 896 [2006]; Matter of Swain v County of Albany, 268 AD2d 747, 749 [2000], lv denied 94 NY2d 764 [2000]). 2006In any event, leave to file a late notice of claim is not appropriate for a patently meritless claim (see Matter of Catherine G. v County of Essex, 3 NY3d 175, 179 [2004]; Matter of Swain v County of Albany, 268 AD2d 747, 749 [2000], lv denied 94 NY2d 764 [2000]). | 2 | 2 |
Swinton v. City of New Yorkgreen1 sentence2025“Leave is not appropriate for a patently meritless claim” (Matter of Catherine G. v County of Essex, 3 NY3d 175, 179 [2004]; Swinton v City of New York, 61 AD3d 557, 558 [1st Dept 2009]). | 1 | 1 |
Diegelman v. City of Buffalogreen2 sentences2016The Appellate Division agreed with the City that the claim was barred by General Municipal Law § 207-c and, thus, held that claimants' application should be denied because "leave to file a late notice - 2 - - 3 - No. 168 of claim is not appropriate for a patently meritless claim" (129 AD3d at 1527 [internal quotation marks and citation omitted]). 2016The Appellate Division agreed with the City that the claim was barred by General Municipal Law § 207-c and, thus, held that claimants’ application should be denied because “leave to file a late notice of claim is not appropriate for a patently meritless claim” (129 AD3d at 1527 [internal quotation marks and citation omitted]). | 1 | 1 |
Ernest v. Red Creek Central School Districtgreen1 sentence2010School Dist., 93 NY2d 664, 671 [1999]; see also Matter of Catherine G. v County of Essex, 3 NY3d 175, 179 [2004] [“(l)eave is not appropriate for a patently meritless claim”]). | 1 | 1 |
Forrest v. Berlin Central School Districtgreen1 sentence2007School Dist., 29 AD3d 1230, 1231 [2006], appeal dismissed 7 NY3d 896 [2006]; Matter of Swain v County of Albany, 268 AD2d 747, 749 [2000], lv denied 94 NY2d 764 [2000]). | 1 | 1 |
Lentini v. Pagegreen1 sentence2006Mandatory reporters, including defendant’s employees, are granted immunity from liability for making good faith child protective reports, such good faith is presumed (see Social Services Law § 419; Lentini v Page, 5 AD3d 914, 915 [2004] ), and the record fails to support plaintiffs conclusory accusations that defendant’s employees filed the report in bad faith. | 1 | 1 |
Katz v. Town of Bedfordgreen1 sentence2004Leave is not appropriate for a patently meritless claim (see also Matter of Katz v Town of Bedford, 192 AD2d 707, 708 [2d Dept 1993]). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in New York. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Damiani v. City of Buffalo
green
2 sentences2015Respondents are correct that the claim is barred by section 207-c (see Damiani v City of Buffalo, 198 AD2d 814 , 814-815 [1993], lv denied 83 NY2d 757 [1994]; see also Dischiavi v Calli, 111 AD3d 1258, 1262 [2013]), and leave to file a late notice of claim “is not appropriate for a patently meritless claim” (Matter of Catherine G. v County of Essex, 3 NY3d 175, 179 [2004]). 2015Respondents are correct that the claim is barred by section 207-c (see Damiani v City of Buffalo, 198 AD2d 814 , 814-815 [1993], lv denied 83 NY2d 757 [1994]; see also Dischiavi v Calli, 111 AD3d 1258, 1262 [2013]), and leave to file a late notice of claim “is not appropriate for a patently meritless claim” (Matter of Catherine G. v County of Essex, 3 NY3d 175, 179 [2004]). | 3 | 2015–2015 |
LEDY v. Molin
neutral
1 sentence2007School Dist., 29 AD3d 1230, 1231 [2006], appeal dismissed 7 NY3d 896 [2006]; Matter of Swain v County of Albany, 268 AD2d 747, 749 [2000], lv denied 94 NY2d 764 [2000]). | 1 | 2007–2007 |