protest error (New York) · Go Syfert
← New York issues

protest error in New York

11 New York opinions name it 3 courts 1922–2015 0 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 (3)

CaseFollowedCited
People v. Narayangreen
ny · 1981 · cited in 3 New York opinions naming this issue, 1985–2015
2 sentences

2015This Court has applied the commonsense principle that if defense counsel is present to bring an error to the trial court’s attention, counsel must register a protest where the error, if called to the court’s attention, “would afford the trial court opportunity promptly to rescind any directive violative of the defendant’s right of access to counsel or otherwise to cure the error” (P eople v Narayan, 54 NY2d 106, 112 [1981]).

2015This Court has applied the common sense principle that if defense counsel is present to bring an error to the trial court's attention, counsel must register a protest where the error, if called to the court's attention, "would afford the trial court opportunity promptly to rescind any directive violative of the defendant's right of access to counsel or otherwise to cure the error" (People v Narayan, 54 NY2d 106, 112 [1981]).

23
City of Rochester v. Chiarellagreen
ny · 1983 · cited in 1 New York opinions naming this issue, 2009–2009
2 sentences

2009Petitioners’ allegation that such an obligation was excused on a “duress” rationale is not supported by our precedent (City of Rochester v Chiarella, 58 NY2d 316, 323 [1983] [“duress ... is present . . . where payment of a tax is necessary to avoid threatened interference with present liberty of person or immediate possession of property”]).

2009Petitioners' allegation that such an obligation was excused on a "duress" rationale is not supported by our precedent ( City of Rochester v Chiarella, 58 NY2d 316, 323 [1983] ["duress . . . is present . . . where payment of a tax is necessary to avoid threatened interference with present liberty of person or immediate possession of property"]).

11
People v. Jonesgreen
nyappdiv · 1981 · cited in 1 New York opinions naming this issue, 1985–1985
1 sentence

1985While we have the discretionary power to reverse a judgment based upon our review of an unpreserved issue when the interest of justice so requires (CPL 470.15; see, People v Jones, 81 AD2d 22 ), the challenged charge error does not require us to do so in the instant case.

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 (11)

CaseCitedYears
Town of Somerset v. Perry green
nyappdiv · 1985
2 sentences

2013Therefore, under the circumstances alleged in the complaint, the protest requirement is inapplicable (see Genesee Brewing Co. v Village of Sodus Point, 126 Misc 2d 827 [1984], affd for reasons stated 115 AD2d 313 [1985]).

2013Therefore, under the circumstances alleged in the complaint, the protest requirement is inapplicable (see Genesee Brewing Co. v Village of Sodus Point, 126 Misc 2d 827 [1984], affd for reasons stated 115 AD2d 313 [1985]).

22013–2013
Genesee Brewing Co. v. Village of Sodus Point green
nysupct · 1984
2 sentences

2013Therefore, under the circumstances alleged in the complaint, the protest requirement is inapplicable (see Genesee Brewing Co. v Village of Sodus Point, 126 Misc 2d 827 [1984], affd for reasons stated 115 AD2d 313 [1985]).

2013Therefore, under the circumstances alleged in the complaint, the protest requirement is inapplicable (see Genesee Brewing Co. v Village of Sodus Point, 126 Misc 2d 827 [1984], affd for reasons stated 115 AD2d 313 [1985]).

22013–2013
People v. Umali green
ny · 2008
2 sentences

2015We reaffirmed that principle in People v Umali ( 10 NY3d 417 [2008]).

2015We reaffirmed that principle in People v Umali ( 10 NY3d 417 , [2008]).

12015–2015
People v. Margan green
nyappdiv · 1990
1 sentence

2011The majority relies on Margan ( 157 AD2d at 70 ) which distinguishes Narayan as standing for the oxymoronic-like proposition that counsel has to be “actually present” at the time an erroneous ruling respecting right to counsel is made in order to object for the record.

12011–2011
Corporate Property Investors v. Board of Assessors green
nyappdiv · 1989
1 sentence

1990Investors v Board of Assessors, 153 AD2d 656 .) In the case at bar, plaintiffs have failed to establish compliance with the protest requirement.

11990–1990
Garden City Center Associates v. Board of Assessors green
nyappdiv · 1989
1 sentence

1989In addition, we note that under this court’s holding in Garden City Center Assocs. v Board of Assessors ( 153 AD2d 667 ), the commencement of the instant proceeding, which included an explicit claim for tax refunds owing as a result of the improper assessments, also satisfied the protest requirement with respect to tax payments made subsequent thereto and while the action was still pending.

11989–1989
Geders v. United States green
scotus · 1976
1 sentence

1981Without in any way depreciating the stature of the constitutionally protected right of a criminal defendant effectively to confer with counsel and not to be deprived of that right of consultation for any substantial period of time (Geders v United States, 425 US 80 ), we find no justification for departing from the requirement that trial court error (here interference with that right) must be brought to the court’s attention by protest timely made, at least where counsel acting on defendant’s behalf is present and available to register a protest and where the error if called to the court’s att

11981–1981
Pisciotta v. City of New York neutral
ny · 1950
1 sentence

1951The right to recover wages in a case such as this is made subject to the condition that failure to note a protest is a bar to recovery in an action for salary differential (Administrative Code, § 93c-2.0; Quayle v. City of New York, 278 N. Y. 19, 24 ; Pisciotta v. City of New York, 300 N. Y. 664 , motion for reargument denied, 300 N. Y. 755 ).

11951–1951
Quayle v. City of New York green
ny · 1938
1 sentence

1951The right to recover wages in a case such as this is made subject to the condition that failure to note a protest is a bar to recovery in an action for salary differential (Administrative Code, § 93c-2.0; Quayle v. City of New York, 278 N. Y. 19, 24 ; Pisciotta v. City of New York, 300 N. Y. 664 , motion for reargument denied, 300 N. Y. 755 ).

11951–1951
Pisciotta v. City of New York neutral
ny · 1950
1 sentence

1951The right to recover wages in a case such as this is made subject to the condition that failure to note a protest is a bar to recovery in an action for salary differential (Administrative Code, § 93c-2.0; Quayle v. City of New York, 278 N. Y. 19, 24 ; Pisciotta v. City of New York, 300 N. Y. 664 , motion for reargument denied, 300 N. Y. 755 ).

11951–1951
United States v. Diekelman green
· 1876
1 sentence

1922As the court said in United States v. Diekelman (supra): “ It rests with the sovereign against whom the demand is made to determine for himself what he will do in respect to it.” In the instant case a defense to the jurisdiction of the court and a protest against its exercise was submitted to the court.

11922–1922

Where else courts name it

TX 42 (1990–2024) OH 37 (1959–2026) NY 11 (1922–2015) CA 10 (1901–2025) WA 7 (1990–2024) AK 5 (1990–2012) MI 3 (2007–2025) GA 2 (1990–2015) IL 2 (1997–2009) DC 2 (1998–2013) UT 2 (1998–2026) MN 2 (1949–1959) CO 2 (2007–2007) NM 2 (2016–2021)

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.

← Caselaw search · G Cite Topics · Brief Check