Hill motion (New York) · Go Syfert
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Hill motion in New York

9 New York opinions name it 2 courts 2008–2026 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 (7)

CaseFollowedCited
Caristo v. Sanzonegreen
ny · 2001 · cited in 3 New York opinions naming this issue, 2014–2014
2 sentences

2014“Under the emergency doctrine, ‘ “when [a driver] is faced with a sudden and unexpected circumstance which leaves little or no time for thought, deliberation or consideration, or causes [the driver] to be reasonably so disturbed that [he or she] must make a speedy decision without weighing alternative courses of conduct, the [driver] may not be negligent if the actions taken are reasonable and prudent in the emergency context, provided the [driver] has not created the emergency” ’ (Caristo v Sanzone, 96 NY2d 172, 174 [2001] [citation omitted]; see Lifson v City of Syracuse, 17 NY3d 492, 497 [2

2014“Under the emergency doctrine, ‘ “when [a driver] is faced with a sudden and unexpected circumstance which leaves little or no time for thought, deliberation or consideration, or causes [the driver] to be reasonably so disturbed that [he or she] must make a speedy decision without weighing alternative courses of conduct, the [driver] may not be negligent if the actions taken are reasonable and prudent in the emergency context, provided the [driver] has not created the emergency” ’ (Caristo v Sanzone, 96 NY2d 172, 174 [2001] [citation omitted]; see Lifson v City of Syracuse, 17 NY3d 492, 497 [2

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

2014“Under the emergency doctrine, ‘ “when [a driver] is faced with a sudden and unexpected circumstance which leaves little or no time for thought, deliberation or consideration, or causes [the driver] to be reasonably so disturbed that [he or she] must make a speedy decision without weighing alternative courses of conduct, the [driver] may not be negligent if the actions taken are reasonable and prudent in the emergency context, provided the [driver] has not created the emergency” ’ (Caristo v Sanzone, 96 NY2d 172, 174 [2001] [citation omitted]; see Lifson v City of Syracuse, 17 NY3d 492, 497 [2

2014“Under the emergency doctrine, ‘ “when [a driver] is faced with a sudden and unexpected circumstance which leaves little or no time for thought, deliberation or consideration, or causes [the driver] to be reasonably so disturbed that [he or she] must make a speedy decision without weighing alternative courses of conduct, the [driver] may not be negligent if the actions taken are reasonable and prudent in the emergency context, provided the [driver] has not created the emergency” ’ (Caristo v Sanzone, 96 NY2d 172, 174 [2001] [citation omitted]; see Lifson v City of Syracuse, 17 NY3d 492, 497 [2

33
Lifson v. City of Syracusegreen
ny · 2011 · cited in 3 New York opinions naming this issue, 2014–2014
2 sentences

2014“Under the emergency doctrine, ‘ “when [a driver] is faced with a sudden and unexpected circumstance which leaves little or no time for thought, deliberation or consideration, or causes [the driver] to be reasonably so disturbed that [he or she] must make a speedy decision without weighing alternative courses of conduct, the [driver] may not be negligent if the actions taken are reasonable and prudent in the emergency context, provided the [driver] has not created the emergency” ’ (Caristo v Sanzone, 96 NY2d 172, 174 [2001] [citation omitted]; see Lifson v City of Syracuse, 17 NY3d 492, 497 [2

2014“Under the emergency doctrine, ‘ “when [a driver] is faced with a sudden and unexpected circumstance which leaves little or no time for thought, deliberation or consideration, or causes [the driver] to be reasonably so disturbed that [he or she] must make a speedy decision without weighing alternative courses of conduct, the [driver] may not be negligent if the actions taken are reasonable and prudent in the emergency context, provided the [driver] has not created the emergency” ’ (Caristo v Sanzone, 96 NY2d 172, 174 [2001] [citation omitted]; see Lifson v City of Syracuse, 17 NY3d 492, 497 [2

33
ELRAC, Inc. v. Suerogreen
nyappdiv · 2007 · cited in 2 New York opinions naming this issue, 2013–2013
2 sentences

2013Hill’s claim for uninsured motorist benefits against the NYCTA, a self-insurer, is subject to the six-year statute of limitations of CPLR 213 (2) (see Matter of ELRAC Inc., v Suero, 38 AD3d 544, 545 [2007]; CPLR 213 [2]; see also Jenkins v State Farm Ins.

2013Hill’s claim for uninsured motorist benefits against the NYCTA, a self-insurer, is subject to the six-year statute of limitations of CPLR 213 (2) (see Matter of ELRAC Inc., v Suero, 38 AD3d 544, 545 [2007]; CPLR 213 [2]; see also Jenkins v State Farm Ins.

22
State v. Smithgreen
wash · 1984 · cited in 1 New York opinions naming this issue, 2026–2026
2 sentences

2026Decisions from other state high courts applying Hill have suggested a similar convergence when a mistaken arrest occurs in the context of a street encounter ( see State v Smith , 102 Wash 2d 449, 453, 688 P2d 146, 149 [1984] [applying Hill but observing that "(i)n the context of this case, 'probable cause' means cause to believe that (the defendant) was the (person) named in the warrant"]; State v Sanders , 339 NW2d 557, 560 [Minn 1983] [citing the Hill rule but holding that the initial stop to ascertain the defendant's identity had to be justified by reasonable suspicion]).

2026Decisions from other state high courts applying Hill have suggested a similar convergence when a mistaken arrest occurs in the context of a street encounter ( see State v Smith , 102 Wash 2d 449, 453, 688 P2d 146, 149 [1984] [applying Hill but observing that "(i)n the context of this case, 'probable cause' means cause to believe that (the defendant) was the (person) named in the warrant"]; State v Sanders , 339 NW2d 557, 560 [Minn 1983] [citing the Hill rule but holding that the initial stop to ascertain the defendant's identity had to be justified by reasonable suspicion]).

11
State v. Sandersgreen
minn · 1983 · cited in 1 New York opinions naming this issue, 2026–2026
2 sentences

2026Decisions from other state high courts applying Hill have suggested a similar convergence when a mistaken arrest occurs in the context of a street encounter ( see State v Smith , 102 Wash 2d 449, 453, 688 P2d 146, 149 [1984] [applying Hill but observing that "(i)n the context of this case, 'probable cause' means cause to believe that (the defendant) was the (person) named in the warrant"]; State v Sanders , 339 NW2d 557, 560 [Minn 1983] [citing the Hill rule but holding that the initial stop to ascertain the defendant's identity had to be justified by reasonable suspicion]).

2026Decisions from other state high courts applying Hill have suggested a similar convergence when a mistaken arrest occurs in the context of a street encounter ( see State v Smith , 102 Wash 2d 449, 453, 688 P2d 146, 149 [1984] [applying Hill but observing that "(i)n the context of this case, 'probable cause' means cause to believe that (the defendant) was the (person) named in the warrant"]; State v Sanders , 339 NW2d 557, 560 [Minn 1983] [citing the Hill rule but holding that the initial stop to ascertain the defendant's identity had to be justified by reasonable suspicion]).

11
People v. Sorianogreen
nyappdiv · 2007 · cited in 1 New York opinions naming this issue, 2008–2008
1 sentence

2008While, unlike Hill’s challenge to the court’s accessorial liability charge, this objection was not preserved, reversal in the interest of justice is warranted (see People v Soriano, 36 AD3d 527, 529 [2007]).

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 (5)

CaseCitedYears
Jenkins v. State Farm Insurance green
nyappdiv · 2005
2 sentences

2013Co., 21 AD3d 529 [2005]).

2013Co., 21 AD3d 529 [2005]).

22013–2013
Gwynn v. Soriano green
nyappdiv · 2010
1 sentence

2019Partners , 96 AD3d 646 [1st Dept 2012]; Kat House Prods., LLC v Paul, Hastings, Janofsky & Walker, LLP , 71 AD3d 580 [1st Dept 2010]).

12019–2019
Oxbow Calcining USA Inc. v. American Industrial Partners green
nyappdiv · 2012
1 sentence

2019Partners , 96 AD3d 646 [1st Dept 2012]; Kat House Prods., LLC v Paul, Hastings, Janofsky & Walker, LLP , 71 AD3d 580 [1st Dept 2010]).

12019–2019
Gaddy v. Eyler green
ny · 1992
1 sentence

2018The defendants failed to meet their respective prima facie burdens of showing that the plaintiff did not sustain a serious injury within the meaning of Insurance Law § 5102(d) as a result of the subject accident ( see Toure v Avis Rent A Car Sys., 98 NY2d 345 ; Gaddy v Eyler, 79 NY2d 955, 956-957 ).

12018–2018
Toure v. Avis Rent a Car Systems, Inc. green
ny · 2002
1 sentence

2018The defendants failed to meet their respective prima facie burdens of showing that the plaintiff did not sustain a serious injury within the meaning of Insurance Law § 5102(d) as a result of the subject accident ( see Toure v Avis Rent A Car Sys., 98 NY2d 345 ; Gaddy v Eyler, 79 NY2d 955, 956-957 ).

12018–2018

Statutes the citing opinions construe

NY § N.Y. Insurance Law § 5102 (4)

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

TX 42 (1900–2026) CA 42 (1954–2026) GA 29 (1974–2026) FL 25 (1955–2025) MO 20 (1953–2025) OH 16 (1996–2026) PA 14 (1974–2025) TN 13 (1998–2016) KS 13 (1889–2020) IL 10 (1985–2025) MS 9 (1956–2017) NY 9 (2008–2026) AR 8 (1990–2019) CT 8 (1995–2017) DC 7 (1992–2011) IN 7 (1978–2019) IA 6 (1989–2021) NC 6 (1956–2017) LA 6 (1904–1997) WA 6 (2014–2018) NV 6 (1998–2021) WY 5 (1991–2025) MT 5 (2000–2018) AZ 5 (1931–2025) NJ 4 (2014–2020) MD 4 (1914–1997) AL 4 (1997–2015) UT 4 (1990–2005) CO 4 (1996–2026) VA 4 (2000–2023) MA 3 (1948–2001) SC 3 (1964–2011) WV 3 (1984–2017) NM 3 (1963–2016) NE 3 (2018–2021) WI 2 (2021–2024) ID 2 (2004–2020) MI 2 (1982–2025) KY 2 (2021–2023)

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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