prima facie case requirement (New York) · Go Syfert
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prima facie case requirement in New York

77 New York opinions name it 13 courts 1915–2026 9 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 (33)

CaseFollowedCited
People v. Caseygreen
ny · 2000 · cited in 28 New York opinions naming this issue, 2003–2026
2 sentences

2015Thus, to satisfy the prima facie case requirement an information must allege completely every element of the offense charged and those allegations must be nonhearsay (see People v Casey, 95 NY2d 354, 362 [2000]; Kalin, 12 NY3d at 229 ; see also People v Fernandez, 20 NY3d 44, 47 [2012]; People v Dreyden, 15 NY3d 100, 103 [2010]).

2013The prima facie case standard for an information comprises two requirements (see People v Casey, 95 NY2d 354, 362 [2000]).

2328
People v. Kalingreen
ny · 2009 · cited in 31 New York opinions naming this issue, 2009–2026
2 sentences

2026This prima facie case requirement " is not the same as the burden of proof beyond a reasonable doubt required at trial, nor does it rise to the level of legally sufficient evidence that is necessary to survive a motion to dismiss based on the proof presented at trial." Kalin, 12 N.Y.3d at 230; see also Henderson, 92 N.Y.2d at 680; People v. Guaman, 22 N.Y.3d 678, 681 (2014).

2026This prima facie case requirement " is not the same as the burden of proof beyond a reasonable doubt required at trial, nor does it rise to the level of legally sufficient evidence that is necessary to survive a motion to dismiss based on the proof presented at trial." Kalin, 12 N.Y.3d at 230 ; see also Henderson, 92 N.Y.2d at 680 ; People v. Guaman, 22 N.Y.3d 678, 681 (2014).

2031
People v. Hendersongreen
ny · 1999 · cited in 23 New York opinions naming this issue, 1999–2026
2 sentences

2026This prima facie case requirement " is not the same as the burden of proof beyond a reasonable doubt required at trial, nor does it rise to the level of legally sufficient evidence that is necessary to survive a motion to dismiss based on the proof presented at trial." Kalin, 12 N.Y.3d at 230; see also Henderson, 92 N.Y.2d at 680; People v. Guaman, 22 N.Y.3d 678, 681 (2014).

2026This prima facie case requirement " is not the same as the burden of proof beyond a reasonable doubt required at trial, nor does it rise to the level of legally sufficient evidence that is necessary to survive a motion to dismiss based on the proof presented at trial." Kalin, 12 N.Y.3d at 230 ; see also Henderson, 92 N.Y.2d at 680 ; People v. Guaman, 22 N.Y.3d 678, 681 (2014).

1823
People v. Alejandrogreen
ny · 1987 · cited in 25 New York opinions naming this issue, 1989–2020
2 sentences

2020The prima facie case standard, which is necessary because of "the unique function that an information serves under the [CPL]," demands that the information contain factual allegations establishing a legally sufficient case against the defendant ( People v Alejandro , 70 NY2d 133, 137, 137-139 [1987]; see People v Jones , 9 NY3d 259, 262 [2007]).

2016(People v Dumay, 23 NY3d 518 [2014]; People v Alejandro, 70 NY2d 133, 138-139 [1987].) Accordingly, a misdemeanor information must set forth “nonhearsay allegations which, if true, establish every element of the offense charged and the defendant’s commission thereof.” (People v Kalin, 12 NY3d 225, 228-229 [2009], citing People v Henderson, 92 NY2d 677, 679 [1999], and CPL 100.40 [1] [c].) This is known as the “prima facie case requirement.” (Kalin, 12 NY3d at 229 [emphasis added].) The prima facie case requirement does not necessitate that the information allege facts that would prove defendan

1225
People v. Jenningsgreen
ny · 1986 · cited in 9 New York opinions naming this issue, 2014–2016
2 sentences

2016(People v Jennings, 69 NY2d 103, 115 [1986].) Rather, the information need only contain allegations of fact that “give an accused notice sufficient to prepare a defense and are adequately detailed to prevent a defendant from being tried twice for the same offense.” (People v Casey, 95 NY2d 354, 360 [2000].) A court reviewing for facial insufficiency must subject the allegations in the information to a “fair and not overly restrictive or technical reading” (id.), assume that those allegations are true, and consider all reasonable inferences that may be drawn from them.

2015The prima facie case requirement does not insist that the information allege facts that would prove defendant’s guilt beyond a reasonable doubt (People v Jennings, 69 NY2d 103, 115 [1986]).

89
People v. Koniecznygreen
ny · 2004 · cited in 5 New York opinions naming this issue, 2009–2025
2 sentences

2025The [*3]Court of Appeals has repeatedly emphasized, "[s]o long as the factual allegations of an information give an accused notice sufficient to prepare a defense and are adequately detailed to prevent a defendant from being tried twice for the same offense, they should be given a fair and not overly restrictive or technical reading." Casey , 95 NY2d at 360 ; see also People v Berrezueta , 31 NY3d 1091, 1092 (2018); Smalls , 26 NY.3d at 1066; People v Dreyden , 15 NY3d 100 (2010); Kalin , 12 NY3d at 230 ; People v Konieczny , 2 NY3d 569, 576 (2004).

2015“So long as the factual allegations of an information give an accused notice sufficient to prepare a defense and are adequately detailed to prevent a defendant from being tried twice for the same offense, [it] should be given a fair and not overly restrictive or technical reading” (People v Casey, 95 NY2d 354, 360 [2000]; People v Konieczny, 2 NY3d 569 [2004]).

45
The People v. Dennis P. Smallsgreen
ny · 2015 · cited in 7 New York opinions naming this issue, 2016–2025
2 sentences

2025The prima facie case requirement in an accusatory instrument "is not the same as the burden of proof beyond a reasonable doubt required at trial, nor does it rise to the level of legally sufficient evidence that is necessary to survive a motion to dismiss based on the proof presented at trial." People v Smalls , 26 NY3d 1064, 1066 (2015) (citations omitted).

2025The prima facie case requirement for the facial sufficiency of an information "is not the same as the burden of proof beyond a reasonable doubt required at trial, nor does it rise to the level of legally sufficient evidence that is necessary to survive a motion to dismiss based on the proof presented at trial" (People v Smalls, 26 N.Y.3d 1064 [2015]).

37
People v. Jonesgreen
ny · 2007 · cited in 3 New York opinions naming this issue, 2015–2020
2 sentences

2020The prima facie case standard, which is necessary because of "the unique function that an information serves under the [CPL]," demands that the information contain factual allegations establishing a legally sufficient case against the defendant ( People v Alejandro , 70 NY2d 133, 137, 137-139 [1987]; see People v Jones , 9 NY3d 259, 262 [2007]).

2015The Court of Appeals has stated that CPL 100.40 (1) places “the burden on the People to make out their prima facie case for the offense charged in the text of the information” (People v Jones, 9 NY3d 259, 261 [2007])- It should be noted that the prima facie case requirement is not the same as the burden required at trial of proof beyond a reasonable doubt, “nor does it rise to the level of legally sufficient evidence that is necessary to survive a motion to dismiss based on the proof presented at trial” (People v Kalin, 12 NY3d 225, 230 [2009]).

33
People v. Dumaygreen
ny · 2014 · cited in 12 New York opinions naming this issue, 2014–2025
2 sentences

2025Although that obligation—known as [*3]"the prima facie case requirement"—applies to an information, "[a] misdemeanor complaint, in comparison, need only set forth facts that establish reasonable cause to believe that the defendant committed the charged offense" ( Dumay , 23 NY3d at 525).

2025Although that obligation—known as [*3]"the prima facie case requirement"—applies to an information, "[a] misdemeanor complaint, in comparison, need only set forth facts that establish reasonable cause to believe that the defendant committed the charged offense" ( Dumay , 23 NY3d at 525 ).

212
In re Jahron S.green
ny · 1992 · cited in 4 New York opinions naming this issue, 2009–2012
2 sentences

2012The dissent disregards this linguistic and historical proof, choosing instead to place emphasis on phrases from People v Alejandro ( 70 NY2d 133 [1987]) and Matter of Jahron S. ( 79 NY2d 632 [1992]) to support its mistaken belief that the prima facie case test is always identical to the legally sufficient evidence standard. 2 We have previously explained that those decisions contain language that was not essential to their holdings and therefore do not bind subsequent cases (see People v Casey, 95 NY2d at 362 ; People v Kalin, 12 NY3d at 232 ).

2012The core holdings of the cases—that the prima facie case rule applies to a juvenile delinquency petition (see Matter of Jahron S., 79 NY2d at 639 ) and that the failure to allege every element of an offense is a jurisdictional defect (see People v Alejandro, 70 NY2d at 136 ; People v Casey, 95 NY2d at 362 )—remain controlling law.

24
People v. Guamangreen
ny · 2014 · cited in 2 New York opinions naming this issue, 2015–2026
2 sentences

2026This prima facie case requirement " is not the same as the burden of proof beyond a reasonable doubt required at trial, nor does it rise to the level of legally sufficient evidence that is necessary to survive a motion to dismiss based on the proof presented at trial." Kalin, 12 N.Y.3d at 230; see also Henderson, 92 N.Y.2d at 680; People v. Guaman, 22 N.Y.3d 678, 681 (2014).

2026This prima facie case requirement " is not the same as the burden of proof beyond a reasonable doubt required at trial, nor does it rise to the level of legally sufficient evidence that is necessary to survive a motion to dismiss based on the proof presented at trial." Kalin, 12 N.Y.3d at 230 ; see also Henderson, 92 N.Y.2d at 680 ; People v. Guaman, 22 N.Y.3d 678, 681 (2014).

22
People v. Allengreen
ny · 1998 · cited in 2 New York opinions naming this issue, 2004–2016
2 sentences

2016(People v Henderson, 92 NY2d 677, 680 [1999].) In reviewing an accusatory instrument for facial insufficiency, “[s]o long as the factual allegations of an information give an accused notice sufficient to prepare a defense and are adequately detailed to prevent a defendant from being tried twice for the same offense, [it] should be given a fair and not overly restrictive or technical reading.” (People v Casey, 95 NY2d 354, 360 [2000].) Moreover, the Court of Appeals, in People v Allen ( 92 NY2d 378, 385 [1998]), held that at the pleading stage, all that is required are factual allegations that

2004The allegations must establish a prima facie case that there is reasonable cause to believe that a defendant is guilty of the crimes charged (People v Allen, 92 NY2d 378, 385 [1998]).

22
People v. Jacksongreen
ny · 2012 · cited in 3 New York opinions naming this issue, 2015–2023
2 sentences

2023Further, he did not explain or describe the Texas "buy tag." These allegations are too conclusory to meet the prima facie case requirement on the issue of whether the buy tag was a forgery ( cf. People v Jackson , 18 NY3d at 746 ; People v Thorne , 50 Misc 3d 775, 776-777 [Crim Ct, Bronx County]).

2022"The requirement that an accusatory instrument contain nonconclusory allegations is part of the prima facie case requirement" ( People v Jackson , 18 NY3d at 746 ).

13
People v. Swampgreen
ny · 1995 · cited in 3 New York opinions naming this issue, 1999–2013
2 sentences

2013Thus, they ask the court to deny the defendant’s motion and to allow them “the opportunity at trial to detail the nature and extent of the injuries suffered by the complainant, and to offer . . . proof that the complainant suffered either substantial pain or impairment of physical condition.” Although the standard for legally sufficient evidence differs in certain respects from the prima facie case standard, they are substantively equivalent (see People v Suber, 19 NY3d 247, 251 [2012]; People v Swamp, 84 NY2d 725, 730 [1995]).

1999(See, People v Henderson, 92 NY2d 677 .) The Court in Henderson , citing People v Gordon ( 88 NY2d 92 , supra) and People v Swamp ( 84 NY2d 725 ), emphasized that a prima facie case requirement is not the same as the burden of proof beyond a reasonable doubt.

13
People v. Dreydengreen
ny · 2010 · cited in 2 New York opinions naming this issue, 2015–2025
2 sentences

2025The [*3]Court of Appeals has repeatedly emphasized, "[s]o long as the factual allegations of an information give an accused notice sufficient to prepare a defense and are adequately detailed to prevent a defendant from being tried twice for the same offense, they should be given a fair and not overly restrictive or technical reading." Casey , 95 NY2d at 360 ; see also People v Berrezueta , 31 NY3d 1091, 1092 (2018); Smalls , 26 NY.3d at 1066; People v Dreyden , 15 NY3d 100 (2010); Kalin , 12 NY3d at 230 ; People v Konieczny , 2 NY3d 569, 576 (2004).

2015Thus, to satisfy the prima facie case requirement an information must allege completely every element of the offense charged and those allegations must be nonhearsay (see People v Casey, 95 NY2d 354, 362 [2000]; Kalin, 12 NY3d at 229 ; see also People v Fernandez, 20 NY3d 44, 47 [2012]; People v Dreyden, 15 NY3d 100, 103 [2010]).

12
People v. Guzmangreen
ny · 1983 · cited in 2 New York opinions naming this issue, 1997–2004
2 sentences

2004(Taylor v Louisiana, 419 US 522 [1975].) In order to establish a prima facie case for violation of the fair cross-section requirement under the 6th Amendment, the defendant must show: “(1) that the group alleged to be excluded is a ‘distinctive’ group in the community; (2) that the representation of this group in venires from which juries are selected is not fair and reasonable in rela tion to the number of such persons in the community; and (3) that this underrepresentation is due to systematic exclusion of the group in the jury-selection process” (Duren v Missouri, 439 US 357, 364 [1979]; se

1997In People v Guzman ( 60 NY2d 403 , cert denied 466 US 951 ), the Court of Appeals held that a group is distinctive if that group constitutes "a substantial and identifiable segment of the community” (supra, at 410). " 'To show that a group is distinct or cognizable under the [8]ixth [A]mendment, a defendant must show: (1) that the group is defined and limited by some factor * * * (2) that a common thread or basic similarity in attitude, ideas, or experience runs through the group; and (3) that there is a community of interest among members of the group such that the group’s interests cannot be

12
People v. Berrezuetagreen
ny · 2018 · cited in 1 New York opinions naming this issue, 2025–2025
1 sentence

2025The [*3]Court of Appeals has repeatedly emphasized, "[s]o long as the factual allegations of an information give an accused notice sufficient to prepare a defense and are adequately detailed to prevent a defendant from being tried twice for the same offense, they should be given a fair and not overly restrictive or technical reading." Casey , 95 NY2d at 360 ; see also People v Berrezueta , 31 NY3d 1091, 1092 (2018); Smalls , 26 NY.3d at 1066; People v Dreyden , 15 NY3d 100 (2010); Kalin , 12 NY3d at 230 ; People v Konieczny , 2 NY3d 569, 576 (2004).

11
People v. Thornegreen
nycrimct · 2015 · cited in 1 New York opinions naming this issue, 2023–2023
1 sentence

2023Further, he did not explain or describe the Texas "buy tag." These allegations are too conclusory to meet the prima facie case requirement on the issue of whether the buy tag was a forgery ( cf. People v Jackson , 18 NY3d at 746 ; People v Thorne , 50 Misc 3d 775, 776-777 [Crim Ct, Bronx County]).

11
People v. Ottogreen
nyappdiv · 2017 · cited in 1 New York opinions naming this issue, 2023–2023
1 sentence

2023Further, even assuming that the information sufficiently alleged that the buy tag was a forgery, the information failed to provide sufficient factual allegations to "establish a presumption that [the] defendant had knowledge of the forged nature of the instrument" ( People v Johnson , 65 NY2d at 561; see People v Brousseau , 149 AD3d at 1277 ).

11
Blakeslee v. Rabinorgreen
nyappdiv · 1992 · cited in 1 New York opinions naming this issue, 2022–2022
1 sentence

2022Therefore, plaintiff is entitled to summary judgment on its cause of action for fraudulent conveyance under § 273-a ( see Blakeslee [*2]v Rabinor, 182 AD2d 390, 391 [1st Dept 1992], lv denied 82 NY2d 655 [1993]).

11
People v. Pearsongreen
nyappdiv · 2010 · cited in 1 New York opinions naming this issue, 2020–2020
11
People v. Fernandezgreen
ny · 2012 · cited in 1 New York opinions naming this issue, 2015–2015
11
People v. Subergreen
ny · 2012 · cited in 1 New York opinions naming this issue, 2013–2013
11
People v. Clarksongreen
nyappdiv · 1975 · cited in 1 New York opinions naming this issue, 2011–2011
11
People v. Lawsgreen
nyappdiv · 1976 · cited in 1 New York opinions naming this issue, 2011–2011
11
People v. Weinberggreen
ny · 1974 · cited in 1 New York opinions naming this issue, 2009–2009
11
People v. Cooksgreen
nyappdiv · 1996 · cited in 1 New York opinions naming this issue, 2005–2005
11
Duren v. Missourigreen
scotus · 1979 · cited in 1 New York opinions naming this issue, 2004–2004
11
Brad Bangerter v. Orem City Corporation, a Utah Municipal Corporationgreen
ca10 · 1995 · cited in 1 New York opinions naming this issue, 1997–1997
11
People v. Goregreen
nycrimct · 1989 · cited in 1 New York opinions naming this issue, 1995–1995
11
Furnco Construction Corp. v. Watersgreen
scotus · 1978 · cited in 1 New York opinions naming this issue, 1989–1989
11
McDonnell Douglas Corp. v. Greengreen
scotus · 1973 · cited in 1 New York opinions naming this issue, 1989–1989
11
Texas Department of Community Affairs v. Burdinegreen
scotus · 1981 · cited in 1 New York opinions naming this issue, 1989–1989
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 (45)

CaseCitedYears
People v. Hyde green
nyappdiv · 2003
2 sentences

2016The prima facie case requirement is a lower threshold than the burden of proof beyond a reasonable doubt required at trial (People v Henderson, 92 NY2d 677, 680 [1999]; People v Hyde, 302 AD2d 101 [1st Dept 2003]).

2005The prima facie case requirement of an accusatory instrument is a lower threshold than the burden of proof beyond a reasonable doubt required at trial (People v Henderson, 92 NY2d 677, 680 [1999]; People v Hyde, 302 AD2d 101 [1st Dept 2003]).

32004–2016
People v. Gordon green
ny · 1996
2 sentences

2009The term “physical injury” is defined by Penal Law § 10.00 (9) as “impairment of physical condition or substantial pain.” Thus, under the prima facie case requirement set forth in CPL 100.40 (1) (c), the information must set forth sufficient factual allegations to warrant the conclusion that the victim suffered an “impairment of physical condition or substantial pain.” However, it must be noted that the prima facie case requirement for pleading purposes is not the same as the burden of proof beyond a reasonable doubt required at trial (see People v Gordon, 88 NY2d 92 [1996]).

1999(See, People v Henderson, 92 NY2d 677 .) The Court in Henderson , citing People v Gordon ( 88 NY2d 92 , supra) and People v Swamp ( 84 NY2d 725 ), emphasized that a prima facie case requirement is not the same as the burden of proof beyond a reasonable doubt.

31999–2009
Alston v. Golub Corp. green
nyappdiv · 1987
2 sentences

1990To be contrasted are those cases involving broken ladders or collapsing scaffolding, where the break or collapse is by itself sufficient to establish a prima facie case of violation of Labor Law § 240 (see, e.g., Alston v Golub Corp., 129 AD2d 916 ; Braun v Dormitory Auth., 118 AD2d 614 ; Harmon v Sager, 106 AD2d 704 ).

1989However, unlike cases involving broken ladders or collapsing scaffoldings, where the break or collapse by itself is sufficient to establish a prima facie case of violation of section 240, since it is unlikely that the scaffolding would collapse or the ladder break if properly constructed (see, Alston v Golub Corp., 129 AD2d 916 ; Braun v Dormitory Auth., 118 AD2d 614 ; Harmon v Sager, 106 AD2d 704 ; Weaver v Lazarus, 93 AD2d 859 ), there is nothing in the present record to indicate that the ladder was not "so constructed, placed and operated as to give proper protection” (Labor Law § 240 [1]).

31989–1992
People v. Voelker green
nycrimct · 1997
2 sentences

2016When ruling on the sufficiency of an information, a court must accept the factual allegations as true (cf. People v Casey, 95 NY2d 354 [2000]; People v Henderson), but the court is limited to reviewing the facts as they are set forth in the four corners of the accusatory document (see People v Voelker, 172 Misc 2d 564 [Crim Ct, NY County 1997, Morgenstern, J.]; cf. CPL 100.40 [1]).

2008When ruling on the sufficiency of an information, a court must accept the factual allegations as true (People v Casey, 95 NY2d 354 [2000]; People v Henderson, supra), but it is limited to reviewing the facts as they are set forth in the four corners of the accusatory document (see People v Voelker, 172 Misc 2d 564 [Crim Ct, Kings County 1997, Morgenstern, J.]; cf. CPL 100.40 [1]), and separate documents must be read separately (see People v Grabinski, 189 Misc 2d 307 [App Term, 2d Dept 2001]).

22008–2016
People v. Minuto green
nybataviacityct · 1972
2 sentences

1995Ctr., 122 Misc 2d 260, 269 , supra [a misdemeanor complaint may rest on hearsay provided it sets forth reasonable grounds to believe that a crime has been committed]; People v Minuto, 71 Misc 2d 800 , supra; People v Gore, 143 Misc 2d 106, 108 [Crim Ct, Kings County 1989], citing People v Alejandro, 70 NY2d 133, 139 , and People v Miles, 64 NY2d 731 [the prima facie case requirement of an information is distinct from the allegations of an evidentiary character required by CPL 100.15].) Defendant’s motion to dismiss the accusatory instrument on the additional ground that the date of occurrence

1989(See, People v Boyer, 105 Misc 2d 877, 884 , revd 116 Misc 2d 931 , revd 58 NY2d 122 ; People v Minuto, 71 Misc 2d 800 .) This subdivision indicates that facts may be added in a supporting deposition which can then satisfy the prima facie case requirement of an information.

21989–1995
People v. Miles green
ny · 1984
2 sentences

1995Ctr., 122 Misc 2d 260, 269 , supra [a misdemeanor complaint may rest on hearsay provided it sets forth reasonable grounds to believe that a crime has been committed]; People v Minuto, 71 Misc 2d 800 , supra; People v Gore, 143 Misc 2d 106, 108 [Crim Ct, Kings County 1989], citing People v Alejandro, 70 NY2d 133, 139 , and People v Miles, 64 NY2d 731 [the prima facie case requirement of an information is distinct from the allegations of an evidentiary character required by CPL 100.15].) Defendant’s motion to dismiss the accusatory instrument on the additional ground that the date of occurrence

1989(See, People v Alejandro, supra, at 139; People v Miles, 64 NY2d 731 .) CPL 140.45 further qualifies that when an instrument based on a warrant-less arrest is not sufficient, "if the court is satisfied that on the basis of the available facts or evidence it would be impossible to draw and file an accusatory instrument which is sufficient”, it must be dismissed.

21989–1995
Harmon v. Sager green
nyappdiv · 1984
2 sentences

1990To be contrasted are those cases involving broken ladders or collapsing scaffolding, where the break or collapse is by itself sufficient to establish a prima facie case of violation of Labor Law § 240 (see, e.g., Alston v Golub Corp., 129 AD2d 916 ; Braun v Dormitory Auth., 118 AD2d 614 ; Harmon v Sager, 106 AD2d 704 ).

1989However, unlike cases involving broken ladders or collapsing scaffoldings, where the break or collapse by itself is sufficient to establish a prima facie case of violation of section 240, since it is unlikely that the scaffolding would collapse or the ladder break if properly constructed (see, Alston v Golub Corp., 129 AD2d 916 ; Braun v Dormitory Auth., 118 AD2d 614 ; Harmon v Sager, 106 AD2d 704 ; Weaver v Lazarus, 93 AD2d 859 ), there is nothing in the present record to indicate that the ladder was not "so constructed, placed and operated as to give proper protection” (Labor Law § 240 [1]).

21989–1990
Braun v. Dormitory Authority neutral
nyappdiv · 1986
2 sentences

1990To be contrasted are those cases involving broken ladders or collapsing scaffolding, where the break or collapse is by itself sufficient to establish a prima facie case of violation of Labor Law § 240 (see, e.g., Alston v Golub Corp., 129 AD2d 916 ; Braun v Dormitory Auth., 118 AD2d 614 ; Harmon v Sager, 106 AD2d 704 ).

1989However, unlike cases involving broken ladders or collapsing scaffoldings, where the break or collapse by itself is sufficient to establish a prima facie case of violation of section 240, since it is unlikely that the scaffolding would collapse or the ladder break if properly constructed (see, Alston v Golub Corp., 129 AD2d 916 ; Braun v Dormitory Auth., 118 AD2d 614 ; Harmon v Sager, 106 AD2d 704 ; Weaver v Lazarus, 93 AD2d 859 ), there is nothing in the present record to indicate that the ladder was not "so constructed, placed and operated as to give proper protection” (Labor Law § 240 [1]).

21989–1990
The People v. Matthew P. green
ny · 2015
1 sentence

2024Failure to meet those demands—what effectively are the "the reasonable cause requirement of section 100.40 (1) (b) [and] the prima facie case requirement of section 100.40 (1) (c)"—is "a jurisdictional defect" ( Matthew P. , 26 NY3d at 335 ).

12024–2024
People v. Patten green
nynyccityct · 2011
1 sentence

2022Thus, where an allegation involves a conclusion, there must be some explanation for the basis of that conclusion that is evident from the accusatory instrument ( see id. ; People v Kalin , 12 NY3d 225, 229 [2009]; People v Patten , 32 Misc 3d at 444-446 ).

12022–2022
People v. Parsons (Jerome) green
nyappterm · 2020
12020–2020
People v. Gonzalez green
nyappterm · 2000
12016–2016
People v. Thomas neutral
nyithacacityct · 2014
12015–2015
People v. Hightower green
ny · 2011
12015–2015
Reich v. Bankers Life & Casualty Co. green
ny · 1986
12015–2015
People v. King green
nyappdiv · 1975
12011–2011
In re Daniel McC. green
nyappdiv · 1998
12011–2011
People v. Bello green
ny · 1998
12010–2010
People v. Fuggazzatto green
ny · 1984
12010–2010
People v. Grabinski neutral
nyappterm · 2001
12008–2008
In re Dirhim A. green
nyappdiv · 1991
12005–2005
In re Jose M. green
nyappdiv · 1991
12005–2005
In re Jose M. neutral
nyappdiv · 1992
12005–2005
In re Jose M. green
nyappdiv · 1992
12005–2005
In re Edward B. green
ny · 1992
12004–2004
Taylor v. Louisiana green
scotus · 1975
12004–2004
People v. Rojas green
ny · 1984
11999–1999
Larkin v. State Of Michigan Department Of Social Services green
ca6 · 1996
11997–1997
Town of Huntington v. Huntington Branch green
scotus · 1989
11997–1997
Huntington Branch, National Association For The Advancement Of Colored People v. The Town Of Huntington green
ca2 · 1988
11997–1997
Seatrain Lines, Inc. v. Carcich green
scotus · 1984
11997–1997
Prozeralik v. Capital Cities Communications, Inc. neutral
ny · 1996
11996–1996
Antunes v. 950 Park Avenue Corp. green
nyappdiv · 1989
11996–1996
Klein v. City of New York green
nyappdiv · 1995
11996–1996
People v. Baron green
nyappterm · 1980
11995–1995
People v. Flushing Hospital & Medical Center green
nycrimct · 1983
11995–1995
In re David T. green
ny · 1990
11992–1992
People v. Potwora green
nyappdiv · 1974
11992–1992
Dick v. John M. Gates Construction Corp. neutral
nyappdiv · 1989
11992–1992
Wescott v. Shear green
nyappdiv · 1990
11992–1992

Statutes the citing opinions construe

NY § N.Y. Penal Law § 215.50 (8) NY § N.Y. Penal Law § 10.00 (7) NY § N.Y. Penal Law § 120.00 (7) NY § N.Y. Penal Law § 110.00 (6) NY § N.Y. Penal Law § 240.26 (6) NY § N.Y. Penal Law § 145.00 (4) NY § N.Y. Penal Law § 15.05 (4) NY § N.Y. Penal Law § 220.03 (4) NY § N.Y. Penal Law § 240.00 (4) NY § N.Y. Penal Law § 240.30 (4) NY § N.Y. Penal Law § 155.25 (3) NY § N.Y. Penal Law § 5.00 (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

IN 134 (1911–2018) NY 77 (1915–2026) TX 40 (1926–2024) IL 25 (1982–2024) NC 13 (1906–2017) OH 13 (1958–2025) WA 12 (1913–2017) CA 11 (1914–2019) MI 10 (1962–2024) MO 9 (1901–2021) WI 9 (1910–2023) LA 8 (2001–2024) PA 7 (1973–2026) TN 6 (1965–2024) ND 6 (2013–2026) FL 6 (1992–2013) IA 5 (2012–2023) AL 5 (1977–2006) CO 5 (1957–2013) MA 5 (1997–2020) AZ 5 (1985–2022) NJ 4 (1998–2024) NM 4 (2017–2024) AR 4 (1993–2000) DC 3 (1987–2007) UT 3 (1989–2003) OR 3 (1954–2010) HI 2 (1939–2016) CT 2 (2001–2002) WY 2 (1978–2007) KY 2 (1922–2017)

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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