explicit waiver (New York) · Go Syfert
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explicit waiver in New York

71 New York opinions name it 6 courts 1878–2025 5 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 (25)

CaseFollowedCited
People v. Outleygreen
ny · 1993 · cited in 3 New York opinions naming this issue, 2014–2014
2 sentences

2014Defendant’s admitted failure to successfully complete inpatient treatment established a breach of that condition of release and supports the sentencing court’s imposition of the enhanced sentence (see People v Outley, 80 NY2d 702, 712-713 [1993]; People v McDevitt, 97 AD3d 1039, 1040-1041 [2012], lv denied 20 NY3d 987 [2012]).

2014Defendant’s admitted failure to successfully complete inpatient treatment established a breach of that condition of release and supports the sentencing court’s imposition of the enhanced sentence (see People v Outley, 80 NY2d 702, 712-713 [1993]; People v McDevitt, 97 AD3d 1039, 1040-1041 [2012], lv denied 20 NY3d 987 [2012]).

33
People v. McDevittgreen
nyappdiv · 2012 · cited in 3 New York opinions naming this issue, 2014–2014
2 sentences

2014Defendant’s admitted failure to successfully complete inpatient treatment established a breach of that condition of release and supports the sentencing court’s imposition of the enhanced sentence (see People v Outley, 80 NY2d 702, 712-713 [1993]; People v McDevitt, 97 AD3d 1039, 1040-1041 [2012], lv denied 20 NY3d 987 [2012]).

2014Defendant’s admitted failure to successfully complete inpatient treatment established a breach of that condition of release and supports the sentencing court’s imposition of the enhanced sentence (see People v Outley, 80 NY2d 702, 712-713 [1993]; People v McDevitt, 97 AD3d 1039, 1040-1041 [2012], lv denied 20 NY3d 987 [2012]).

33
People v. Diazgreen
nyappdiv · 2006 · cited in 3 New York opinions naming this issue, 2014–2014
2 sentences

2014To the extent that defendant’s contention that his admissions to the allegations contained in the violation of probation petition were not voluntary, knowing or intelligent is preserved, the record reflects that defendant’s counseled admissions were freely entered, after advisement of his rights, an opportunity to confer with his counsel and an explicit waiver of his right to a hearing (see People v Diaz, 26 AD3d 644, 645 [2006], lv denied 7 NY3d 755 [2006]).

2014To the extent that defendant’s contention that his admissions to the allegations contained in the violation of probation petition were not voluntary, knowing or intelligent is preserved, the record reflects that defendant’s counseled admissions were freely entered, after advisement of his rights, an opportunity to confer with his counsel and an explicit waiver of his right to a hearing (see People v Diaz, 26 AD3d 644, 645 [2006], lv denied 7 NY3d 755 [2006]).

33
Santa Clara Pueblo v. Martinezgreen
scotus · 1978 · cited in 3 New York opinions naming this issue, 2012–2012
2 sentences

2012Group, Inc. v Oneida Indian Nation, 53 AD3d 1048, 1049 [2008], lv denied 11 NY3d 709 [2008] [internal quotation marks omitted]; see Santa Clara Pueblo v Martinez, 436 US 49, 58-59 [1978]; Matter of Ransom v St.

2012Group, Inc. v Oneida Indian Nation, 53 AD3d 1048, 1049 [2008], lv denied 11 NY3d 709 [2008] [internal quotation marks omitted]; see Santa Clara Pueblo v Martinez, 436 US 49, 58-59 [1978]; Matter of Ransom v St.

33
People v. Velasquezgreen
ny · 2003 · cited in 4 New York opinions naming this issue, 2014–2025
2 sentences

2022An explicit waiver of defendant's right to be present occurs [*4]when a defendant either personally or through his counsel makes an affirmative statement on the record to the effect that he is waving such right, that is , that he does not wish to attend the sidebar conference ( see People v Velazquez , 1 NY3d at 47-50 ; People v Keen , 94 NY2d at 538-539 ).

2022An explicit waiver of defendant's right to be present occurs [*4]when a defendant either personally or through his counsel makes an affirmative statement on the record to the effect that he is waving such right, that is , that he does not wish to attend the sidebar conference ( see People v Velazquez , 1 NY3d at 47-50 ; People v Keen , 94 NY2d at 538-539 ).

24
People v. Carmodygreen
nyappdiv · 2008 · cited in 3 New York opinions naming this issue, 2012–2012
2 sentences

2012Group, Inc. v Oneida Indian Nation, 53 AD3d 1048, 1049 [2008], lv denied 11 NY3d 709 [2008] [internal quotation marks omitted]; see Santa Clara Pueblo v Martinez, 436 US 49, 58-59 [1978]; Matter of Ransom v St.

2012Group, Inc. v Oneida Indian Nation, 53 AD3d 1048, 1049 [2008], lv denied 11 NY3d 709 [2008] [internal quotation marks omitted]; see Santa Clara Pueblo v Martinez, 436 US 49, 58-59 [1978]; Matter of Ransom v St.

23
People v. Vargasgreen
ny · 1996 · cited in 2 New York opinions naming this issue, 2014–2025
2 sentences

2025While it is true that the trial court need not engage the defendant in any particular colloquy to obtain a waiver ( see People v Velasquez , 1 NY3d 44, 49 [2003]), it is also true that such a waiver must be the product of a "voluntary, knowing and intelligent choice" on the defendant's part ( People v Vargas , 88 NY2d 363, 375-376 [1996]).

2014It is hard to imagine how his decision not to attend could have been affected if the court here had used the word “right.” As for the explicit waiver, we have repeatedly held that a lawyer may waive the Antommarchi right of his or her client (People v Velasquez, 1 NY3d 44, 47-50 [2003]; People v Keen, 94 NY2d 533, 538-539 [2000]; see also People v Vargas, 88 NY2d 363, 376 [1996] [because sidebar presence is a statutory, not a constitutional, right, “this Court has been more flexible regarding the acceptable form of voluntary waivers by defendants and their lawyers”]).

22
Leon v. Martinezgreen
ny · 1994 · cited in 2 New York opinions naming this issue, 2015–2015
2 sentences

2015On a CPLR 3211 motion to dismiss, the Court accepts facts as alleged in the complaint as true, accords the plaintiff the benefit of every possible favorable inference, and determines whether the facts as alleged fit within any cognizable legal theory (Leon v Martinez, 84 NY2d 83, 87-88 [1994]).

2015On a CPLR 3211 motion to dismiss, the Court accepts facts as alleged in the complaint as true, accords the plaintiff the benefit of every possible favorable inference, and determines whether the facts as alleged fit within any cognizable legal theory (Leon v Martinez, 84 NY2d 83, 87-88 [1994]).

22
People v. Keengreen
ny · 2000 · cited in 3 New York opinions naming this issue, 2014–2022
2 sentences

2022An explicit waiver of defendant's right to be present occurs [*4]when a defendant either personally or through his counsel makes an affirmative statement on the record to the effect that he is waving such right, that is , that he does not wish to attend the sidebar conference ( see People v Velazquez , 1 NY3d at 47-50 ; People v Keen , 94 NY2d at 538-539 ).

2022An explicit waiver of defendant's right to be present occurs [*4]when a defendant either personally or through his counsel makes an affirmative statement on the record to the effect that he is waving such right, that is , that he does not wish to attend the sidebar conference ( see People v Velazquez , 1 NY3d at 47-50 ; People v Keen , 94 NY2d at 538-539 ).

13
Matter of Arbitration Between Gleason & Michael Vee, Ltd.green
ny · 2001 · cited in 1 New York opinions naming this issue, 2025–2025
1 sentence

2025As the VGM created a new, broader cause of action under New York law that expanded upon the protections offered by the VAWA, it did not merely clarify or reaffirm existing law ( see Matter of Gleason [Michael Vee, Ltd.] , 96 NY2d 117, 122 [2001]).

11
Nalvarte v. Long Island Universitygreen
nyappdiv · 2017 · cited in 1 New York opinions naming this issue, 2018–2018
1 sentence

2018Univ. , 153 AD3d 712, 713-714 [2d Dept 2015]).

11
Cahill v. TRIBOROUGHgreen
ny · 2004 · cited in 1 New York opinions naming this issue, 2018–2018
1 sentence

2018Triable issues of fact exist as to whether plaintiff was instructed to demolish the wall from top to bottom, and whether any decision by plaintiff to work from the bottom up, in contravention of an explicit instruction or in contravention of his training or common knowledge, was the sole proximate cause of the accident ( see Cahill v Triborough Bridge and Tunnel Auth. , 4 NY3d 35, 39-40 [2004]; Nalvarte v Long Is.

11
People v. Jenksgreen
nyappdiv · 2010 · cited in 1 New York opinions naming this issue, 2011–2011
1 sentence

2011Similarly, inasmuch as defendant’s claim of ineffective assistance of counsel pertains to counsel’s representation at a pre-plea suppression hearing and does not impact on the voluntariness of his subsequent plea, it does not survive the waiver of appeal (see People v Gentry, 73 AD3d 1383, 1384 [2010]) and, is, in any event, unpreserved for our review (see People v Jenks, 69 AD3d 1120, 1121 [2010], lv denied 14 NY3d 841 [2010]).

11
People v. Gentrygreen
nyappdiv · 2010 · cited in 1 New York opinions naming this issue, 2011–2011
1 sentence

2011Similarly, inasmuch as defendant’s claim of ineffective assistance of counsel pertains to counsel’s representation at a pre-plea suppression hearing and does not impact on the voluntariness of his subsequent plea, it does not survive the waiver of appeal (see People v Gentry, 73 AD3d 1383, 1384 [2010]) and, is, in any event, unpreserved for our review (see People v Jenks, 69 AD3d 1120, 1121 [2010], lv denied 14 NY3d 841 [2010]).

11
People v. Simmonsgreen
nyappdiv · 2006 · cited in 1 New York opinions naming this issue, 2011–2011
1 sentence

2011Defendant’s claims regarding deficiencies in the grand jury proceedings are precluded from our review by defendant’s knowing, intelligent and voluntary guilty plea, which included an explicit waiver of his right to appeal (see People v Simmons, 27 AD3d 786, 787 [2006], lv denied 7 NY3d 763 [2006]; People v Robertson, 279 AD2d 711, 712 [2001], lv denied 96 NY2d 805 [2001]).

11
People v. Robertsongreen
nyappdiv · 2001 · cited in 1 New York opinions naming this issue, 2011–2011
1 sentence

2011Defendant’s claims regarding deficiencies in the grand jury proceedings are precluded from our review by defendant’s knowing, intelligent and voluntary guilty plea, which included an explicit waiver of his right to appeal (see People v Simmons, 27 AD3d 786, 787 [2006], lv denied 7 NY3d 763 [2006]; People v Robertson, 279 AD2d 711, 712 [2001], lv denied 96 NY2d 805 [2001]).

11
Butterfield v. Board of Trustees of Schenectady County Community Collegegreen
nyappdiv · 1987 · cited in 1 New York opinions naming this issue, 2010–2010
1 sentence

2010A notice of claim must be served upon the local sponsor, however, if that local sponsor would otherwise be entitled to a notice of claim (see Education Law § 6308 [3], [6]; Butterfield v Board of Trustees of Schenectady County Community Coll., 131 AD2d 963, 964 [1987]).

11
People ex rel. Gill v. Greenegreen
ny · 2009 · cited in 1 New York opinions naming this issue, 2010–2010
1 sentence

2010Gill v Greene, 12 NY3d 1, 6 [2009], cert denied sub nom.

11
Clay Dome & Golf Center, LLC v. Board of Assessorsgreen
nyappdiv · 2002 · cited in 1 New York opinions naming this issue, 2007–2007
11
270 Riverside Drive, Inc. v. Braungreen
nyappterm · 2004 · cited in 1 New York opinions naming this issue, 2005–2005
11
Sullivan v. Brevard Associatesgreen
ny · 1985 · cited in 1 New York opinions naming this issue, 2005–2005
11
People v. Nelsongreen
ny · 1987 · cited in 1 New York opinions naming this issue, 1999–1999
11
People v. Munizgreen
ny · 1998 · cited in 1 New York opinions naming this issue, 1998–1998
11
People v. Ellettgreen
nyappdiv · 1997 · cited in 1 New York opinions naming this issue, 1998–1998
11
Prue v. Huntgreen
ny · 1991 · cited in 1 New York opinions naming this issue, 1996–1996
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 (55)

CaseCitedYears
ELMIRA TEACHERS'ASSN. v. Elmira City School Dist. green
ny · 2008
2 sentences

2012Group, Inc. v Oneida Indian Nation, 53 AD3d 1048, 1049 [2008], lv denied 11 NY3d 709 [2008] [internal quotation marks omitted]; see Santa Clara Pueblo v Martinez, 436 US 49, 58-59 [1978]; Matter of Ransom v St.

2012Group, Inc. v Oneida Indian Nation, 53 AD3d 1048, 1049 [2008], lv denied 11 NY3d 709 [2008] [internal quotation marks omitted]; see Santa Clara Pueblo v Martinez, 436 US 49, 58-59 [1978]; Matter of Ransom v St.

32012–2012
People v. Moissett green
ny · 1990
2 sentences

2019Indeed, in People v Moissett, we held that the defendant validly waived his right to appeal, -3- -4- Nos. 87, 88, 89 overlooking the fact that “the record [did] not reveal an explicit waiver” ( 76 NY2d at 911 ).

1990Memorandum: Although the record does not reveal an explicit waiver by defendant of his right to appeal, there is ample evidence in the record to conclude that defendant understood that he was waiving that right as part of his plea bargain and that the waiver was voluntary, knowing and intelligent (see, People v Moissett, 76 NY2d 909 ; People v Seaberg, 74 NY2d 1, 12 ).

21990–2019
In Re the Arbitration Between Buffalo Police Benevolent Ass'n & City of Buffalo green
ny · 2005
2 sentences

2012This is not a situation where the safety of the community is involved (cf. Buffalo Police Benevolent Assn., 4 NY3d at 664 ), and we thus conclude that public policy does not require an explicit waiver.

2012This is not a situation where the safety of the community is involved (cf. Buffalo Police Benevolent Assn., 4 NY3d at 664 ), and we thus conclude that public policy does not require an explicit waiver.

22012–2012
People v. Seaberg green
ny · 1989
2 sentences

1995As a result of this broad and explicit waiver (see, People v Allen, 82 NY2d 761, 763 ), which we also find to have been voluntarily, knowingly and intelligently made (see, People v Seaberg, 74 NY2d 1, 11 ), defendant has relinquished his right to appellate review of County Court’s denial of his suppression motion (see, People v Williams, 36 NY2d 829, 830 , cert denied 423 US 873 ; People v Torres, supra, at 417 ; People v Hayes, supra, at 1000 ).

1990Memorandum: Although the record does not reveal an explicit waiver by defendant of his right to appeal, there is ample evidence in the record to conclude that defendant understood that he was waiving that right as part of his plea bargain and that the waiver was voluntary, knowing and intelligent (see, People v Moissett, 76 NY2d 909 ; People v Seaberg, 74 NY2d 1, 12 ).

21990–1995
Farag v. Farag green
nyappdiv · 2004
1 sentence

2024Further, neither translation of the Mahr agreement contains an explicit waiver of equitable distribution, maintenance, or counsel fees ( see Farag v Farag , 4 AD3d 502, 504 ).

12024–2024
The People v. Rasaun Sanders green
ny · 2015
1 sentence

2019Decades later, in People v Sanders, we upheld an appeal waiver comprised only of three questions posed by the prosecutor, who conducted the entire colloquy without input from the trial court ( 25 NY3d at 339-340 ).

12019–2019
Storozynski v. Storozynski green
nyappdiv · 2004
1 sentence

2017(Storozynski v Storozynski, 10 AD3d 419 [2d Dept 2004].) To be clear, Mr. D. did not try to amend the contract with regard to the annuity nor did he negotiate his ex-wife’s waiver of her interest in it when the separation agreement was prepared.

12017–2017
People v. Tyrell green
ny · 2013
1 sentence

2017The record in this case fails to exhibit that defendant "intelligently and understandingly rejected his constitutional rights," as required, by establishing that defendant either consulted with his attorney or by an explicit waiver of his rights as to each charge pled on the record ( id. ).

12017–2017
In re the Estate of De Roo green
nysurct · 1990
1 sentence

2012In the absence of an explicit waiver referencing EPTL 5-3.1, the language of the agreement must otherwise clearly indicate an intention to relinquish the right to the exempt property (see Matter of Dito, 218 AD2d 737 [1995]; Matter of De Roo, 148 Misc 2d 856 [1990]).

12012–2012
In re Dito green
nyappdiv · 1995
1 sentence

2012In the absence of an explicit waiver referencing EPTL 5-3.1, the language of the agreement must otherwise clearly indicate an intention to relinquish the right to the exempt property (see Matter of Dito, 218 AD2d 737 [1995]; Matter of De Roo, 148 Misc 2d 856 [1990]).

12012–2012
People v. Healy green
ny · 2010
1 sentence

2011Similarly, inasmuch as defendant’s claim of ineffective assistance of counsel pertains to counsel’s representation at a pre-plea suppression hearing and does not impact on the voluntariness of his subsequent plea, it does not survive the waiver of appeal (see People v Gentry, 73 AD3d 1383, 1384 [2010]) and, is, in any event, unpreserved for our review (see People v Jenks, 69 AD3d 1120, 1121 [2010], lv denied 14 NY3d 841 [2010]).

12011–2011
Norton Co. v. Assessor of Watervliet green
nyappdiv · 2002
1 sentence

2009It is also notable that Avis was decided just one year after 22 NYCRR 678.3 was renumbered and reenacted as the current section 202.59, with the explicit requirement that owner-occupied premises be considered income-producing “as determined by the amount reasonably allocable for rent,” although the petitioner “is not required to make an estimate of rental income.” (Uniform Rules for Trial Courts [22 NYCRR] § 202.59 [b].) White Plains was also cited more recently by the Third Department in Matter of Norton Co. v Assessor of City of Watervliet ( 292 AD2d 672 [3d Dept 2002]).

12009–2009
Ransom v. ST. REGIS FUND green
ny · 1995
12008–2008
Hopkins v. New York State Board of Parole green
nyappdiv · 2008
12008–2008
MATTER OF CHUBB GROUP OF INS. COS. v. Williams green
ny · 2005
12007–2007
Premier Self Storage of Lancaster v. Fusco green
nyappdiv · 2004
12007–2007
Mayer v. St. Mary's School green
nyappdiv · 2005
12007–2007
Kern v. City of Rochester green
nyappdiv · 1999
12007–2007
Pines v. Muss Development Co. green
nyappdiv · 1991
12003–2003
Reed v. City of New York green
nyappdiv · 2003
12003–2003
People v. Hansen green
ny · 2000
12001–2001
Four Aces Jewelry Corp. v. Smith green
nyappdiv · 1998
12001–2001
People v. Lynch green
nyappdiv · 1998
12001–2001
People v. Arroya green
nyappdiv · 2000
12001–2001
People v. Alexander neutral
nyappdiv · 2000
12001–2001
People v. Pelchat green
ny · 1984
12001–2001
In re New York County DES Litigation green
nyappdiv · 1991
12000–2000
People v. Johnson green
nyappdiv · 1992
12000–2000
Muniz v. Preferred Associates green
nyappdiv · 1993
12000–2000
People v. Poleto neutral
nyappdiv · 1998
12000–2000
Furch v. Bucci green
nyappdiv · 1998
12000–2000
People v. Mingues green
nyappdiv · 1998
12000–2000
Roman v. Turner Colours, Inc. green
nyappdiv · 1998
12000–2000
People v. Johnson green
nyappdiv · 1999
12000–2000
People v. Hidalgo green
ny · 1998
11998–1998
People v. Callahan green
ny · 1992
11998–1998
People v. Prentice green
nyappdiv · 1991
11998–1998
People v. Prescott neutral
nyappdiv · 1993
11998–1998
State v. General Electric Co. green
nyappdiv · 1993
11998–1998
People v. Dixon green
nyappdiv · 1994
11998–1998

Statutes the citing opinions construe

USC § 28u.s.c.1610 (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

CA 115 (1919–2026) IL 88 (1902–2026) TX 72 (1978–2026) NY 71 (1878–2025) PA 65 (1931–2025) IA 47 (1873–2024) WA 41 (1965–2024) MA 31 (1979–2026) OH 29 (1993–2025) CT 29 (1821–2021) DC 23 (1978–2019) AZ 22 (1956–2025) TN 22 (1933–2026) NJ 22 (1975–2024) MI 22 (1923–2024) NC 22 (1889–2024) FL 21 (1988–2022) NM 18 (1978–2026) IN 16 (1979–2019) WI 15 (1978–2020) AL 15 (1861–2024) MS 15 (1882–2024) LA 14 (1903–2018) KY 13 (1935–2025) MO 13 (1858–2018) VA 12 (1930–2026) MN 12 (1985–2014) MD 12 (1957–2013) OR 11 (1968–2023) DE 11 (1975–2026) NE 11 (1940–2026) CO 11 (1981–2014) UT 10 (2001–2025) GA 10 (1999–2025) HI 9 (1955–2026) VT 9 (1962–2014) OK 9 (1915–2025) MT 8 (2005–2025) AK 8 (1987–2025) KS 8 (2001–2024) ME 8 (1990–2025) SD 6 (1924–2014) SC 6 (1981–2016) NV 6 (1879–2022) AR 5 (1898–2009) NH 4 (1991–2025) WY 4 (1992–2012) ND 4 (1977–2018) ID 4 (1968–2024) WV 2 (1995–1996) VI 2 (1997–2003)

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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