constitutional tort claim (New York) · Go Syfert
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constitutional tort claim in New York

8 New York opinions name it 2 courts 2002–2024 2 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 (5)

CaseFollowedCited
Martinez v. City of Schenectadygreen
ny · 2001 · cited in 4 New York opinions naming this issue, 2002–2018
2 sentences

2009A constitutional tort claim is barred when a claimant has an alternative legal remedy to protect his or her constitutional rights (see Martinez v City of Schenectady, 97 NY2d 78, 83-84 [2001]; Bullard v State of New York, 307 AD2d 676, 678-679 [2003]).

2006Moreover, in Martinez , the Court clarified that such a right is a “narrow” one and indicated that recognition of a constitutional tort claim is not necessary where the claimant has an alternate “avenue of redress” (Martinez v City of Schenectady, supra at 83).

34
Shelton v. New York State Liquor Authoritygreen
nyappdiv · 2009 · cited in 3 New York opinions naming this issue, 2018–2024
2 sentences

2024Auth. , 61 AD3d 1145, 1151 [3d Dept 2009][citations omitted]; see also Brown v State of New York , 89 NY2d 172, 185 [1996] [citations omitted] [the State is not a "person" subject to a lawsuit pursuant to 42 USC 1983, which is the statute authorizing private parties to enforce their federal constitutional rights via lawsuits]).

2024Auth. , 61 AD3d 1145, 1151 [3d Dept 2009][citations omitted]; see also Brown v State of New York , 89 NY2d 172, 185 [1996] [citations omitted] [the State is not a "person" subject to a lawsuit pursuant to 42 USC 1983, which is the statute authorizing private parties to enforce their federal constitutional rights via lawsuits]).

33
Brown v. State of New Yorkgreen
ny · 1996 · cited in 3 New York opinions naming this issue, 2009–2024
2 sentences

2024Auth. , 61 AD3d 1145, 1151 [3d Dept 2009][citations omitted]; see also Brown v State of New York , 89 NY2d 172, 185 [1996] [citations omitted] [the State is not a "person" subject to a lawsuit pursuant to 42 USC 1983, which is the statute authorizing private parties to enforce their federal constitutional rights via lawsuits]).

2009Since the proposed claim appears to assert causes of action for the intentional tort of false imprisonment (CPLR 215 [3] [a one-year statute of limitations]), and a constitutional tort for violation of claimant’s rights (CPLR 214 [5] [a three-year statute of limitations]; see Brown v State of New York, 89 NY2d 172 [1996]), the motion is properly before the court.

33
Bullard v. Stategreen
nyappdiv · 2003 · cited in 2 New York opinions naming this issue, 2009–2018
2 sentences

2018Auth. , 61 AD3d 1145, 1150 [2009]; see Martinez v City of Schenectady , 97 NY2d 78, 83-84 [2001]; Bullard v State of New York , 307 AD2d 676, 678 [2003]).

2009A constitutional tort claim is barred when a claimant has an alternative legal remedy to protect his or her constitutional rights (see Martinez v City of Schenectady, 97 NY2d 78, 83-84 [2001]; Bullard v State of New York, 307 AD2d 676, 678-679 [2003]).

22
Plate v. Stategreen
nyclaimsct · 1978 · cited in 1 New York opinions naming this issue, 2009–2009
1 sentence

2009Next, in determining whether to grant a motion to file a late claim, Court of Claims Act § 10 (6) sets forth six factors that should be considered, although other factors deemed relevant also may be taken into account (Plate v State of New York, 92 Misc 2d 1033, 1036 [Ct Cl 1978]).

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 (2)

CaseCitedYears
Rodriguez v. City of New York green
nyappdiv · 2011
1 sentence

2015The allegations in the instant claim, that sewage covered 85% of the claimant’s cell for a period of nearly 12 hours, if true, may give rise to a constitutional tort claim for violation of the prohibition against cruel and inhuman treatment (cf. Rodriguez v City of New York, 87 AD3d 867 [1st Dept 2011] [allegations of a slippery floor condition were not sufficiently serious to constitute cruel and inhuman punishment]).

12015–2015
Scott v. Smith green
nyappdiv · 2013
1 sentence

2015To the extent claimant alleges that prison staff ignored a supervisor’s direct order to provide the claimant with a means to clean the unsanitary conditions in his cell, he sufficiently alleged the requisite state of mind necessary to survive a motion to dismiss for failure to state a cause of action (cf. Scott v Smith, 104 AD3d 1029 [3d Dept 2013]).

12015–2015

Statutes the citing opinions construe

USC § 42u.s.c.1983 (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

MI 21 (2002–2024) NY 8 (2002–2024) IA 6 (2018–2025) VT 3 (2018–2019) CA 2 (2000–2002) SD 2 (1997–2003) OK 2 (2018–2018) MD 2 (2002–2005) PA 2 (2018–2022)

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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