Patterson rule (New York) · Go Syfert
← New York issues

Patterson rule in New York

10 New York opinions name it 4 courts 1992–2026 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 (10)

CaseFollowedCited
Hadar v. Piercegreen
nyappdiv · 2013 · cited in 2 New York opinions naming this issue, 2014–2014
2 sentences

2014Plaintiffs contend that they pleaded distinct allegations as against Rosenbaum that are outside the scope of the privilege, but those allegations also pertain to conduct undertaken by Rosenbaum as counsel for Eric’s father, Richard Hadar, in preparation for the litigation, and they are insufficient to distinguish the claims against him from those against the Patterson defendants (see Hadar I, 111 AD3d at 439; Art Capital Group, LLC v Neuhaus, 70 AD3d 605 [1st Dept 2010]).

2014Plaintiffs contend that they pleaded distinct allegations as against Rosenbaum that are outside the scope of the privilege, but those allegations also pertain to conduct undertaken by Rosenbaum as counsel for Eric’s father, Richard Hadar, in preparation for the litigation, and they are insufficient to distinguish the claims against him from those against the Patterson defendants (see Hadar I, 111 AD3d at 439; Art Capital Group, LLC v Neuhaus, 70 AD3d 605 [1st Dept 2010]).

22
Chateau D' If Corp. v. City of New Yorkgreen
nyappdiv · 1996 · cited in 2 New York opinions naming this issue, 2014–2014
2 sentences

2014Although Rosenbaum only argued that the defamation claim should be dismissed on the ground of the judicial proceedings privilege, our prior decision is controlling here, pursuant to the doctrine of stare decisis, and, under the circumstances, the issue can be raised for the first time on appeal (see Chateau D’ If Corp. v City of New York, 219 AD2d 205, 209 [1st Dept 1996], lv denied 88 NY2d 811 [1996]).

2014Although Rosenbaum only argued that the defamation claim should be dismissed on the ground of the judicial proceedings privilege, our prior decision is controlling here, pursuant to the doctrine of stare decisis, and, under the circumstances, the issue can be raised for the first time on appeal (see Chateau D’ If Corp. v City of New York, 219 AD2d 205, 209 [1st Dept 1996], lv denied 88 NY2d 811 [1996]).

22
The People v. Chris Pricegreen
ny · 2017 · cited in 1 New York opinions naming this issue, 2026–2026
1 sentence

2026Proper authentication of evidence vindicates the basic principle that evidence which is not what the proponent claims it to be can prove nothing at all ( Price , 29 NY3d at 476 ["In order for a piece of evidence to be of probative value, there must be proof that it is what its proponent says it is"], quoting United States v Sliker , 751 F2d 477, 497 [2d Cir 1984]).

11
Zegarelli v. Hughesgreen
ny · 2004 · cited in 1 New York opinions naming this issue, 2026–2026
1 sentence

2026The authentication requirement applies to civil as well as criminal proceedings ( see Zegarelli v Hughes , 3 NY3d 64, 69 [2004] [applying Patterson standard for authentication of videotape in civil context]).

11
Palka v. Servicemaster Management Services Corp.green
ny · 1994 · cited in 1 New York opinions naming this issue, 2016–2016
1 sentence

2016Corp., 83 NY2d 579, 588 [1994]), and whether the Patterson defendants breached a duty to the decedent.

11
Espinal v. Melville Snow Contractors, Inc.green
ny · 2002 · cited in 1 New York opinions naming this issue, 2016–2016
2 sentences

2016“Generally, a contractual obligation, standing alone, will not give rise to tort liability in favor of a third party” (Cioffi v Klein, 119 AD3d 886, 888 [2014]; see Espinal v Melville Snow Contrs., 98 NY2d 136, 140 [2002]).

2016However, the Patterson defendants failed to meet their prima facie burden of establishing that they had not entirely displaced the decedent’s duty to maintain the premises safely (see Espinal v Melville Snow Contrs., 98 NY2d at 140 ).

11
Cioffi v. Kleingreen
nyappdiv · 2014 · cited in 1 New York opinions naming this issue, 2016–2016
1 sentence

2016“Generally, a contractual obligation, standing alone, will not give rise to tort liability in favor of a third party” (Cioffi v Klein, 119 AD3d 886, 888 [2014]; see Espinal v Melville Snow Contrs., 98 NY2d 136, 140 [2002]).

11
People v. Graygreen
ny · 1995 · cited in 1 New York opinions naming this issue, 1999–1999
2 sentences

1999The Patterson rule “goes to the general and over-all procedure of the trial, forbidding alteration of mandated procedural, structural, and process-oriented standards” (People v Gray, 86 NY2d 10, 21 [emphasis in original]).

1999The Patterson rule “goes to the general and over-all procedure of the trial, forbidding alteration of mandated procedural, structural, and process-oriented standards” (People v Gray, 86 NY2d 10, 21 [emphasis in original]).

11
Coleman v. Domino's Pizza, Inc.green
alsd · 1990 · cited in 1 New York opinions naming this issue, 1993–1993
2 sentences

1993Further, the weight of authority is that under the Patterson rule, termination of a contract is not covered by section 1981 (see, Lavender v V & B Transmissions & Auto Repair, 897 F2d 805; Overby v Chevron USA, 884 F2d 470, 473; Long v AT & T Information Sys., 733 F Supp 188 ; Doffoney v Board of Trustees, 731 F Supp 781 ; Coleman v Domino’s Pizza, 728 F Supp 1528, 1531-1532, n 3 ; Alexander v New York Med.

1993Further, the weight of authority is that under the Patterson rule, termination of a contract is not covered by section 1981 (see, Lavender v V & B Transmissions & Auto Repair, 897 F2d 805; Overby v Chevron USA, 884 F2d 470, 473; Long v AT & T Information Sys., 733 F Supp 188 ; Doffoney v Board of Trustees, 731 F Supp 781 ; Coleman v Domino’s Pizza, 728 F Supp 1528, 1531-1532, n 3 ; Alexander v New York Med.

11
Brereton v. Communications Satellite Corp.green
dcd · 1990 · cited in 1 New York opinions naming this issue, 1993–1993
2 sentences

1993Significantly, in construing analogous cases, Federal courts have rejected attempts to circumvent the Patterson rule by the plaintiffs who have merely recast "postformation” claims as purported "preformation” discrimination, i.e., claims that an individual "is not only performing under an existing contract but also is constantly 'remaking’ a new contract so that whenever the employee is discriminatorily terminated, the employer has impaired his or her right to 'make’ a contract in violation of § 1981” (Brereton v Communications Satellite Corp., 735 F Supp 1085, 1088 ).

1993Significantly, in construing analogous cases, Federal courts have rejected attempts to circumvent the Patterson rule by the plaintiffs who have merely recast "postformation” claims as purported "preformation” discrimination, i.e., claims that an individual "is not only performing under an existing contract but also is constantly 'remaking’ a new contract so that whenever the employee is discriminatorily terminated, the employer has impaired his or her right to 'make’ a contract in violation of § 1981” (Brereton v Communications Satellite Corp., 735 F Supp 1085, 1088 ).

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 (13)

CaseCitedYears
Arnold v. New York State Division of Human Rights green
nyappdiv · 2010
2 sentences

2014Plaintiffs contend that they pleaded distinct allegations as against Rosenbaum that are outside the scope of the privilege, but those allegations also pertain to conduct undertaken by Rosenbaum as counsel for Eric’s father, Richard Hadar, in preparation for the litigation, and they are insufficient to distinguish the claims against him from those against the Patterson defendants (see Hadar I, 111 AD3d at 439; Art Capital Group, LLC v Neuhaus, 70 AD3d 605 [1st Dept 2010]).

2014Plaintiffs contend that they pleaded distinct allegations as against Rosenbaum that are outside the scope of the privilege, but those allegations also pertain to conduct undertaken by Rosenbaum as counsel for Eric’s father, Richard Hadar, in preparation for the litigation, and they are insufficient to distinguish the claims against him from those against the Patterson defendants (see Hadar I, 111 AD3d at 439; Art Capital Group, LLC v Neuhaus, 70 AD3d 605 [1st Dept 2010]).

22014–2014
In re Quadon H. neutral
nycfamct · 2007
1 sentence

2007Accordingly, it cannot be said that the use of the 2006 print "had no bearing" on the respondent's identification.{** 18 Misc 3d at 372 } It is a basic rule of statutory construction that statutes are to be interpreted in accordance with their plain meaning. ( People v Floyd J. , 61 NY2d 895 [1984].) Here, Family Court Act § 354.1 mandates the destruction of respondent's 2006 fingerprints because the 2006 arrest did not result in the filing of any criminal proceeding against him.

12007–2007
People v. Floyd J. green
ny · 1984
1 sentence

2007Accordingly, it cannot be said that the use of the 2006 print "had no bearing" on the respondent's identification.{** 18 Misc 3d at 372 } It is a basic rule of statutory construction that statutes are to be interpreted in accordance with their plain meaning. ( People v Floyd J. , 61 NY2d 895 [1984].) Here, Family Court Act § 354.1 mandates the destruction of respondent's 2006 fingerprints because the 2006 arrest did not result in the filing of any criminal proceeding against him.

12007–2007
California v. Byers green
scotus · 1971
1 sentence

1996(California v Byers, 402 US 424, 427 .) This court after considering Patterson’s claim of privilege allowed such evidence finding no violation of Patterson’s right against self-incrimination.

11996–1996
People v. Thomas green
ny · 1980
2 sentences

1995However, in People v Thomas ( 50 NY2d 467, 472 ), we stated that a jury charge that is merely capable of being interpreted in such a way as to shift the burden of proof is not a Patterson error.

1995However, in People v Thomas ( 50 NY2d 467, 472 ), we stated that a jury charge that is merely capable of being interpreted in such a way as to shift the burden of proof is not a Patterson error.

11995–1995
Long v. AT & T Information Systems Inc. green
nysd · 1990
2 sentences

1993Further, the weight of authority is that under the Patterson rule, termination of a contract is not covered by section 1981 (see, Lavender v V & B Transmissions & Auto Repair, 897 F2d 805; Overby v Chevron USA, 884 F2d 470, 473; Long v AT & T Information Sys., 733 F Supp 188 ; Doffoney v Board of Trustees, 731 F Supp 781 ; Coleman v Domino’s Pizza, 728 F Supp 1528, 1531-1532, n 3 ; Alexander v New York Med.

1993Further, the weight of authority is that under the Patterson rule, termination of a contract is not covered by section 1981 (see, Lavender v V & B Transmissions & Auto Repair, 897 F2d 805; Overby v Chevron USA, 884 F2d 470, 473; Long v AT & T Information Sys., 733 F Supp 188 ; Doffoney v Board of Trustees, 731 F Supp 781 ; Coleman v Domino’s Pizza, 728 F Supp 1528, 1531-1532, n 3 ; Alexander v New York Med.

11993–1993
Doffoney v. Board of Trustees for Beaumont Independent School District neutral
txed · 1989
2 sentences

1993Further, the weight of authority is that under the Patterson rule, termination of a contract is not covered by section 1981 (see, Lavender v V & B Transmissions & Auto Repair, 897 F2d 805; Overby v Chevron USA, 884 F2d 470, 473; Long v AT & T Information Sys., 733 F Supp 188 ; Doffoney v Board of Trustees, 731 F Supp 781 ; Coleman v Domino’s Pizza, 728 F Supp 1528, 1531-1532, n 3 ; Alexander v New York Med.

1993Further, the weight of authority is that under the Patterson rule, termination of a contract is not covered by section 1981 (see, Lavender v V & B Transmissions & Auto Repair, 897 F2d 805; Overby v Chevron USA, 884 F2d 470, 473; Long v AT & T Information Sys., 733 F Supp 188 ; Doffoney v Board of Trustees, 731 F Supp 781 ; Coleman v Domino’s Pizza, 728 F Supp 1528, 1531-1532, n 3 ; Alexander v New York Med.

11993–1993
Alexander v. New York Medical College green
nysd · 1989
2 sentences

1993Coll., 721 F Supp 587 ; Rivera v AT & T Information Sys., 719 F Supp 962 ; Hall v County of Cook, 719 F Supp 721 ; Nolan’s Auto Body Shop v Allstate Ins.

1993Coll., 721 F Supp 587 ; Rivera v AT & T Information Sys., 719 F Supp 962 ; Hall v County of Cook, 719 F Supp 721 ; Nolan’s Auto Body Shop v Allstate Ins.

11993–1993
Hall v. County of Cook, State of Ill. green
ilnd · 1989
2 sentences

1993Coll., 721 F Supp 587 ; Rivera v AT & T Information Sys., 719 F Supp 962 ; Hall v County of Cook, 719 F Supp 721 ; Nolan’s Auto Body Shop v Allstate Ins.

1993Coll., 721 F Supp 587 ; Rivera v AT & T Information Sys., 719 F Supp 962 ; Hall v County of Cook, 719 F Supp 721 ; Nolan’s Auto Body Shop v Allstate Ins.

11993–1993
Rivera v. AT & T Information Systems, Inc. green
cod · 1989
2 sentences

1993Coll., 721 F Supp 587 ; Rivera v AT & T Information Sys., 719 F Supp 962 ; Hall v County of Cook, 719 F Supp 721 ; Nolan’s Auto Body Shop v Allstate Ins.

1993Coll., 721 F Supp 587 ; Rivera v AT & T Information Sys., 719 F Supp 962 ; Hall v County of Cook, 719 F Supp 721 ; Nolan’s Auto Body Shop v Allstate Ins.

11993–1993
People v. Morgan green
ny · 1990
1 sentence

1992Yes.” Defendant contends that while Patterson’s plea allocution constituted a declaration against penal interests it should not have been admitted against defendant as an exception to the hearsay rule because County Court’s refusal to accept Patterson’s plea until he provided additional facts inculpating defendant gave Patterson a probable motive to misrepresent the facts (see, People v Morgan, 76 NY2d 493 ; People v Thomas, supra).

11992–1992
Myslakowski v. United States green
scotus · 1987
1 sentence

1992We note, initially, that defense counsel, while arguing that defendant’s case was distinguishable from People v Thomas ( 68 NY2d 194 , cert denied 480 US 948 ), did not specifically object to the admission of the plea allocution.

11992–1992
People v. Thomas green
ny · 1986
2 sentences

1992We note, initially, that defense counsel, while arguing that defendant’s case was distinguishable from People v Thomas ( 68 NY2d 194 , cert denied 480 US 948 ), did not specifically object to the admission of the plea allocution.

1992Yes.” Defendant contends that while Patterson’s plea allocution constituted a declaration against penal interests it should not have been admitted against defendant as an exception to the hearsay rule because County Court’s refusal to accept Patterson’s plea until he provided additional facts inculpating defendant gave Patterson a probable motive to misrepresent the facts (see, People v Morgan, 76 NY2d 493 ; People v Thomas, supra).

11992–1992

Where else courts name it

IN 80 (1978–2026) CA 15 (1990–2024) NJ 13 (2017–2026) TX 13 (1921–2025) OH 13 (2001–2026) GA 12 (1988–2025) IL 11 (1986–2022) NY 10 (1992–2026) CT 8 (2007–2021) FL 7 (2000–2019) AL 6 (2004–2024) NV 4 (2013–2022) UT 4 (1995–2017) DE 4 (2010–2023) AZ 4 (2004–2025) WI 4 (2000–2020) LA 4 (1990–2010) WV 3 (1986–2022) DC 3 (1989–2010) PA 3 (1968–2023) MO 3 (1992–2019) NE 3 (1987–2019) VA 3 (1986–2006) WY 2 (2025–2025) MD 2 (2010–2021) NM 2 (2018–2019) AK 2 (2017–2022) KS 2 (2020–2021) MN 2 (2003–2011) ID 2 (2000–2014) MS 2 (1993–2015) OK 2 (2000–2004)

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