second element test (New York) · Go Syfert
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second element test in New York

11 New York opinions name it 4 courts 1976–2026 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 (12)

CaseFollowedCited
City of Cuyahoga Falls v. Buckeye Community Hope Foundationgreen
scotus · 2003 · cited in 2 New York opinions naming this issue, 2004–2009
2 sentences

2009“As for the second element of the test, ‘only the most egregious official conduct can be said to be arbitrary in the constitutional sense’ ” (Bower Assoc. v Town of Pleasant Val., 2 NY3d at 628 , quoting Cuyahoga Falls v Buckeye Community Hope Foundation, 538 US 188, 198 [2003]; St.

2004As for the second element of the test, “only the most egregious official conduct can be said to be arbitrary in the constitutional sense” (City of Cuyahoga Falls, Ohio v Buckeye Community Hope Found., 538 US 188, 198 [2003] [internal quotation marks omitted]; see also Harlen, 273 F3d at 501 [board action based on community opposition is not unconstitutionally arbitrary “if the opposition is based on legitimate state interests such as, inter alia, traffic, safety, crime, community pride, or noise” *629 (internal quotation marks omitted)]; Natale, 170 F3d at 263 [“(s)ubstantive due process stand

22
Zodkevitch v. Feibushgreen
nyappdiv · 2008 · cited in 1 New York opinions naming this issue, 2026–2026
1 sentence

2026Defendants are correct that, generally, a preliminary injunction is unavailable where the alleged injury can be adequately compensated by an award of monetary damages (see Zodkevitch v Feibush, 49 AD3d 424, 425 [2008]).

11
Massie v. Crawfordgreen
ny · 1991 · cited in 1 New York opinions naming this issue, 2009–2009
1 sentence

2009Massie v Crawford, 78 NY2d at 516 [continuous treatment doctrine inapplicable where routine periodic gynecological examinations were not related to the pelvic inflammatory disease allegedly caused by the intrauterine device installed by the physician 14 years earlier]; Davis v City of New York, 38 NY2d at 259-260 [contacts by telephone and mail nearly two years after the alleged malpractice insufficient to constitute medical services]).

11
Nykorchuck v. Henriquesgreen
ny · 1991 · cited in 1 New York opinions naming this issue, 2009–2009
1 sentence

2009A second element of the doctrine is that the course of treatment provided by the physician be for the same conditions or complaints underlying the plaintiffs medical malpractice claim (see Nykorchuck v Henriques, 78 NY2d at 259; Borgia v City of New York, 12 NY2d 151, 157 [1962]; Couch v County of Suffolk, 296 AD2d 194, 197 [2002]; Lane v Feinberg, 293 AD2d 654 [2002]; Grassman v Slovin, 206 AD2d 504 [1994]; see e.g.

11
St. Joseph Hospital v. Novellogreen
nyappdiv · 2007 · cited in 1 New York opinions naming this issue, 2009–2009
1 sentence

2009Joseph Hosp. of Cheektowaga v Novello, 43 AD3d 139, 144 [2007]).

11
Borgia v. City of New Yorkgreen
ny · 1962 · cited in 1 New York opinions naming this issue, 2009–2009
1 sentence

2009A second element of the doctrine is that the course of treatment provided by the physician be for the same conditions or complaints underlying the plaintiffs medical malpractice claim (see Nykorchuck v Henriques, 78 NY2d at 259; Borgia v City of New York, 12 NY2d 151, 157 [1962]; Couch v County of Suffolk, 296 AD2d 194, 197 [2002]; Lane v Feinberg, 293 AD2d 654 [2002]; Grassman v Slovin, 206 AD2d 504 [1994]; see e.g.

11
Davis v. City of New Yorkgreen
ny · 1975 · cited in 1 New York opinions naming this issue, 2009–2009
1 sentence

2009Massie v Crawford, 78 NY2d at 516 [continuous treatment doctrine inapplicable where routine periodic gynecological examinations were not related to the pelvic inflammatory disease allegedly caused by the intrauterine device installed by the physician 14 years earlier]; Davis v City of New York, 38 NY2d at 259-260 [contacts by telephone and mail nearly two years after the alleged malpractice insufficient to constitute medical services]).

11
Couch v. County of Suffolkgreen
nyappdiv · 2002 · cited in 1 New York opinions naming this issue, 2009–2009
1 sentence

2009A second element of the doctrine is that the course of treatment provided by the physician be for the same conditions or complaints underlying the plaintiffs medical malpractice claim (see Nykorchuck v Henriques, 78 NY2d at 259; Borgia v City of New York, 12 NY2d 151, 157 [1962]; Couch v County of Suffolk, 296 AD2d 194, 197 [2002]; Lane v Feinberg, 293 AD2d 654 [2002]; Grassman v Slovin, 206 AD2d 504 [1994]; see e.g.

11
Paul Natale Wendy Natale Jarrod Natale v. Town of Ridgefield Ridgefield Planning and Zoning Commissiongreen
ca2 · 1999 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004As for the second element of the test, “only the most egregious official conduct can be said to be arbitrary in the constitutional sense” (City of Cuyahoga Falls, Ohio v Buckeye Community Hope Found., 538 US 188, 198 [2003] [internal quotation marks omitted]; see also Harlen, 273 F3d at 501 [board action based on community opposition is not unconstitutionally arbitrary “if the opposition is based on legitimate state interests such as, inter alia, traffic, safety, crime, community pride, or noise” *629 (internal quotation marks omitted)]; Natale, 170 F3d at 263 [“(s)ubstantive due process stand

11
Harlen Associates v. The Incorporated Village of Mineola and Board of Trustees for the Incorporated Village of Mineolagreen
ca2 · 2001 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004As for the second element of the test, “only the most egregious official conduct can be said to be arbitrary in the constitutional sense” (City of Cuyahoga Falls, Ohio v Buckeye Community Hope Found., 538 US 188, 198 [2003] [internal quotation marks omitted]; see also Harlen, 273 F3d at 501 [board action based on community opposition is not unconstitutionally arbitrary “if the opposition is based on legitimate state interests such as, inter alia, traffic, safety, crime, community pride, or noise” *629 (internal quotation marks omitted)]; Natale, 170 F3d at 263 [“(s)ubstantive due process stand

11
Revak v. SEC Realty Corp.green
ca2 · 1994 · cited in 1 New York opinions naming this issue, 1998–1998
1 sentence

1998Commn. v Life Partners, supra, at 543; see also, Revak v SEC Realty Corp., 18 F3d 81, 87 ).

11
Securities and Exchange Commission v. Life Partners, Incorporated and Brian D. Pardogreen
cadc · 1996 · cited in 1 New York opinions naming this issue, 1998–1998
1 sentence

1998Commn. v Life Partners, supra, at 543; see also, Revak v SEC Realty Corp., 18 F3d 81, 87 ).

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
People v. Patterson green
ny · 1976
2 sentences

1992While the passage of time alone is not sufficient to defeat, as a matter of law, a claim of extreme emotional disturbance (see, People v Patterson, 39 NY2d 288, 303 , affd 432 US 197 ), there nevertheless remains the need for some proof that a temporally remote provocative act affected the defendant at the time of the homicide to such a degree that a jury could reasonably conclude that he acted under the influence of an extreme emotional disturbance.

1976The Court of Appeals has only recently upheld the constitutionality of this burden distinguishing that ruling from the decision of the Supreme Court of the United States in Mullaney v Wilbur ( 421 US 684 ), which held that a Maine statute, with similar objectives, was unconstitutional (Patterson, 39 NY2d 288 , supra).

21976–1992
Morejon v. Rais Construction Co. green
ny · 2006
1 sentence

2010Co., 7 NY3d at 209 ).

12010–2010
Bower Associates v. Town of Pleasant Valley green
ny · 2004
1 sentence

2009“As for the second element of the test, ‘only the most egregious official conduct can be said to be arbitrary in the constitutional sense’ ” (Bower Assoc. v Town of Pleasant Val., 2 NY3d at 628 , quoting Cuyahoga Falls v Buckeye Community Hope Foundation, 538 US 188, 198 [2003]; St.

12009–2009
Grassman v. Slovin neutral
nyappdiv · 1994
1 sentence

2009A second element of the doctrine is that the course of treatment provided by the physician be for the same conditions or complaints underlying the plaintiffs medical malpractice claim (see Nykorchuck v Henriques, 78 NY2d at 259; Borgia v City of New York, 12 NY2d 151, 157 [1962]; Couch v County of Suffolk, 296 AD2d 194, 197 [2002]; Lane v Feinberg, 293 AD2d 654 [2002]; Grassman v Slovin, 206 AD2d 504 [1994]; see e.g.

12009–2009
Lane v. Feinberg green
nyappdiv · 2002
1 sentence

2009A second element of the doctrine is that the course of treatment provided by the physician be for the same conditions or complaints underlying the plaintiffs medical malpractice claim (see Nykorchuck v Henriques, 78 NY2d at 259; Borgia v City of New York, 12 NY2d 151, 157 [1962]; Couch v County of Suffolk, 296 AD2d 194, 197 [2002]; Lane v Feinberg, 293 AD2d 654 [2002]; Grassman v Slovin, 206 AD2d 504 [1994]; see e.g.

12009–2009
Uhr v. East Greenbush Central School District green
ny · 1999
1 sentence

2004School Dist., supra).

12004–2004
Lisa's Party City, Inc. v. Town Of Henrietta green
ca2 · 1999
1 sentence

2004As for the second element of the test, “only the most egregious official conduct can be said to be arbitrary in the constitutional sense” (City of Cuyahoga Falls, Ohio v Buckeye Community Hope Found., 538 US 188, 198 [2003] [internal quotation marks omitted]; see also Harlen, 273 F3d at 501 [board action based on community opposition is not unconstitutionally arbitrary “if the opposition is based on legitimate state interests such as, inter alia, traffic, safety, crime, community pride, or noise” *629 (internal quotation marks omitted)]; Natale, 170 F3d at 263 [“(s)ubstantive due process stand

12004–2004
Patterson v. New York green
scotus · 1977
1 sentence

1992While the passage of time alone is not sufficient to defeat, as a matter of law, a claim of extreme emotional disturbance (see, People v Patterson, 39 NY2d 288, 303 , affd 432 US 197 ), there nevertheless remains the need for some proof that a temporally remote provocative act affected the defendant at the time of the homicide to such a degree that a jury could reasonably conclude that he acted under the influence of an extreme emotional disturbance.

11992–1992
People v. Calvano green
ny · 1972
1 sentence

1989Such proof of criminality was, of course, competent on the predisposition issue raised by the entrapment defense (People v Calvano, 30 NY2d 199, 205 ), but defendant’s prior and present criminal life was only one of several factors that the jury was bound to weigh.

11989–1989
People v. Settles green
ny · 1978
1 sentence

1986These two prerequisites in particular involve a "delicate balance of diverse factors * * * entrusted to the sound judgment of the trial court, which is aptly suited to weigh the circumstances surrounding the declaration and the evidence used to bolster its reliability” (People v Settles, 46 NY2d, at p 169 , supra).

11986–1986
Mullaney v. Wilbur green
scotus · 1975
1 sentence

1976The Court of Appeals has only recently upheld the constitutionality of this burden distinguishing that ruling from the decision of the Supreme Court of the United States in Mullaney v Wilbur ( 421 US 684 ), which held that a Maine statute, with similar objectives, was unconstitutional (Patterson, 39 NY2d 288 , supra).

11976–1976

Where else courts name it

NC 65 (1995–2019) OH 55 (1983–2026) CA 38 (1957–2026) TX 33 (1961–2025) IL 21 (1989–2026) UT 13 (2000–2024) WI 12 (1980–2024) NM 11 (2004–2024) NY 11 (1976–2026) ID 11 (1966–2021) WY 9 (1992–2016) WA 9 (1992–2024) MI 8 (1972–2023) GA 7 (1993–2018) MA 7 (2000–2021) IA 6 (1980–2023) RI 6 (1980–2013) MO 6 (1992–2014) IN 6 (1982–2025) PA 6 (1982–2022) DE 5 (1975–2025) MD 5 (1994–2019) VA 5 (1989–2023) CT 4 (2002–2025) TN 4 (1954–2007) DC 4 (1981–2025) CO 3 (1983–2024) AL 3 (1980–2024) OR 3 (1985–2026) NJ 3 (2010–2021) AZ 3 (2006–2017) ME 2 (2005–2021) FL 2 (1984–2000) SD 2 (1986–2025) LA 2 (2006–2016) ND 2 (1982–2000) HI 2 (1995–1995)

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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