apparent violation (New York) · Go Syfert
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apparent violation in New York

59 New York opinions name it 12 courts 1890–2026 4 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 (18)

CaseFollowedCited
People v. Brockgreen
nyappdiv · 2013 · cited in 3 New York opinions naming this issue, 2017–2022
2 sentences

2022Thus, automobile stops are lawful when based on probable cause that a driver has committed a traffic violation ( People v Robinson , 97 NY2d 341, 349-350 [2001]). [2] Contrary to defendant's contention, the credible evidence at the Mapp / Dunaway hearing, where the detective testified{**78 Misc 3d at 6} that he stopped defendant's vehicle for having "excessively tinted windows," was sufficient to establish that the detective had probable cause to lawfully stop the "vehicle due to an apparent violation of Vehicle and Traffic Law § 375 (12-a) (b) (2)" ( People v Rowe , 189 AD3d 894 , 895 [2d Dep

2020The credible evidence at the hearing established [*2]that the police officers lawfully stopped the defendant's vehicle due to an apparent violation of Vehicle and Traffic Law § 375(12-a)(b)(2) ( see People v Vanderpool , 157 AD3d 831 ; People v Bacquie , 154 AD3d 648, 649 ; People v Brock , 107 AD3d 1025, 1026-1027 ; People v Collins , 105 AD3d 1378, 1379 ).

13
Pratt v. Habergreen
nyappdiv · 2013 · cited in 1 New York opinions naming this issue, 2026–2026
1 sentence

2026The doctrine of apparent/ostensible agency requires proof of "words or conduct by the hospital" giving rise to a reasonable belief that the physician possessed authority to act on behalf of the hospital, and reasonable reliance by the patient on that perceived relationship (Pratt v Haber, 105 AD3d 429, 429 [1st Dept 2013]; Welch, 21 AD3d at 807 ).

11
Nix v. Whitesidegreen
scotus · 1986 · cited in 1 New York opinions naming this issue, 2026–2026
2 sentences

2026The discovery statute's interlocking provisions place clear duties upon both parties to approach discovery disputes with mutual good-faith, accommodation, reasonableness and 'due diligence,' which is 'a familiar and flexible standard that requires the [parties] to make reasonable efforts to comply with statutory directives' " ( McCray , 2024 NY Slip Op 50760[U], *8 , quoting Bay , 41 NY3d at 211; see People v DePallo , 96 NY2d 437, 441 [2001] ["an attorney's duty to zealously represent a client is circumscribed by an 'equally solemn duty to comply with the law and standards of professional con

2026The discovery statute's interlocking provisions place clear duties upon both parties to approach discovery disputes with mutual good-faith, accommodation, reasonableness and 'due diligence,' which is 'a familiar and flexible standard that requires the [parties] to make reasonable efforts to comply with statutory directives' " ( McCray , 2024 NY Slip Op 50760[U], *8, quoting Bay , 41 NY3d at 211; see People v DePallo , 96 NY2d 437, 441 [2001] ["an attorney's duty to zealously represent a client is circumscribed by an 'equally solemn duty to comply with the law and standards of professional cond

11
People v. DePallogreen
ny · 2001 · cited in 1 New York opinions naming this issue, 2026–2026
2 sentences

2026The discovery statute's interlocking provisions place clear duties upon both parties to approach discovery disputes with mutual good-faith, accommodation, reasonableness and 'due diligence,' which is 'a familiar and flexible standard that requires the [parties] to make reasonable efforts to comply with statutory directives' " ( McCray , 2024 NY Slip Op 50760[U], *8 , quoting Bay , 41 NY3d at 211; see People v DePallo , 96 NY2d 437, 441 [2001] ["an attorney's duty to zealously represent a client is circumscribed by an 'equally solemn duty to comply with the law and standards of professional con

2026The discovery statute's interlocking provisions place clear duties upon both parties to approach discovery disputes with mutual good-faith, accommodation, reasonableness and 'due diligence,' which is 'a familiar and flexible standard that requires the [parties] to make reasonable efforts to comply with statutory directives' " ( McCray , 2024 NY Slip Op 50760[U], *8, quoting Bay , 41 NY3d at 211; see People v DePallo , 96 NY2d 437, 441 [2001] ["an attorney's duty to zealously represent a client is circumscribed by an 'equally solemn duty to comply with the law and standards of professional cond

11
People v. Mitchellgreen
nyappdiv · 2017 · cited in 1 New York opinions naming this issue, 2025–2025
1 sentence

2025Here, the police conduct was justified in light of the defendant's apparent violation of Code of the Village of Hempstead § 95-14, i.e., the Village of Hempstead's open-container law, and the defendant's conduct while interacting with the police ( see People v Mack , 49 AD3d 1291, 1291-1292 ; People v Bothwell , 261 AD2d 232, 234-235 ; see also People v Mitchell , 148 AD3d 730, 731 ; People v Pace , 143 AD3d 1286, 1287 ).

11
People v. Maninigreen
ny · 1992 · cited in 1 New York opinions naming this issue, 2022–2022
1 sentence

2022Moreover, the detective's testimony at the hearing that he noticed, in plain view, a mason jar filled with marihuana in the cup holder of the front center console of the vehicle was sufficient to establish that the arrest was lawful, since the officer had probable cause to believe that the marihuana was, contrary to defendant's contention, readily accessible and available to defendant who was in close proximity to the marihuana, such that the factual circumstances support an inference of defendant's dominion and control over the marihuana ( see People v Manini , 79 NY2d 561, 573 [1992]; People

11
People v. Cartergreen
nyappdiv · 2009 · cited in 1 New York opinions naming this issue, 2022–2022
1 sentence

2022Moreover, the detective's testimony at the hearing that he noticed, in plain view, a mason jar filled with marihuana in the cup holder of the front center console of the vehicle was sufficient to establish that the arrest was lawful, since the officer had probable cause to believe that the marihuana was, contrary to defendant's contention, readily accessible and available to defendant who was in close proximity to the marihuana, such that the factual circumstances support an inference of defendant's dominion and control over the marihuana ( see People v Manini , 79 NY2d 561, 573 [1992]; People

11
People v. Robinsongreen
ny · 2001 · cited in 1 New York opinions naming this issue, 2022–2022
1 sentence

2022Thus, automobile stops are lawful when based on probable cause that a driver has committed a traffic violation ( People v Robinson , 97 NY2d 341, 349-350 [2001]). [2] Contrary to defendant's contention, the credible evidence at the Mapp / Dunaway hearing, where the detective testified{**78 Misc 3d at 6} that he stopped defendant's vehicle for having "excessively tinted windows," was sufficient to establish that the detective had probable cause to lawfully stop the "vehicle due to an apparent violation of Vehicle and Traffic Law § 375 (12-a) (b) (2)" ( People v Rowe , 189 AD3d 894 , 895 [2d Dep

11
In re Spectacular Limo Link, Inc.green
nyappdiv · 2005 · cited in 1 New York opinions naming this issue, 2020–2020
1 sentence

2020The dispatch system would match the driver with work once the driver decided when and where to work ( compare Matter of Spectacular Limo Link, Inc. [Commissioner of Labor] , 21 AD3d 1172, 1173 [2005]).

11
People v. Omowalegreen
nyappdiv · 2011 · cited in 1 New York opinions naming this issue, 2019–2019
11
People v. Thomasgreen
nyappdiv · 2005 · cited in 1 New York opinions naming this issue, 2019–2019
1 sentence

2019The police had, at least, an objective credible reason to approach defendant's stationary vehicle and ask for basic identification information, since the vehicle was double-parked, which constituted a traffic infraction ( see People v Omowale , 83 AD3d 614, 618 [2011], affd 18 NY3d 825 [2011]; People v Citron , 255 AD2d 452 [1998], lv denied 92 NY2d 1030 [1998]) and had a piece of cardboard with handwritten numbers and letters instead of a rear license plate, an apparent violation of Vehicle and Traffic Law § 402(1)(a) ( see People v Ocasio , 85 NY2d 982, 984 [1995] ; People v Thomas , 19 AD3d

11
People v. Ocasiogreen
ny · 1995 · cited in 1 New York opinions naming this issue, 2019–2019
1 sentence

2019The police had, at least, an objective credible reason to approach defendant's stationary vehicle and ask for basic identification information, since the vehicle was double-parked, which constituted a traffic infraction ( see People v Omowale , 83 AD3d 614, 618 [2011], affd 18 NY3d 825 [2011]; People v Citron , 255 AD2d 452 [1998], lv denied 92 NY2d 1030 [1998]) and had a piece of cardboard with handwritten numbers and letters instead of a rear license plate, an apparent violation of Vehicle and Traffic Law § 402(1)(a) ( see People v Ocasio , 85 NY2d 982, 984 [1995] ; People v Thomas , 19 AD3d

11
Leibowits v. Leibowitsgreen
nyappdiv · 1983 · cited in 1 New York opinions naming this issue, 2008–2008
11
Williams v. Alexandergreen
ny · 1955 · cited in 1 New York opinions naming this issue, 2004–2004
11
Longo v. Tafarogreen
ny · 1988 · cited in 1 New York opinions naming this issue, 1998–1998
11
Brill v. Winggreen
nynd · 1996 · cited in 1 New York opinions naming this issue, 1997–1997
11
Ranalli v. Burnsgreen
nyappdiv · 1990 · cited in 1 New York opinions naming this issue, 1995–1995
11
Gardner v. Broderickgreen
scotus · 1968 · cited in 1 New York opinions naming this issue, 1976–1976
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 (62)

CaseCitedYears
People v. Collins green
nyappdiv · 2013
2 sentences

2020The credible evidence at the hearing established [*2]that the police officers lawfully stopped the defendant's vehicle due to an apparent violation of Vehicle and Traffic Law § 375(12-a)(b)(2) ( see People v Vanderpool , 157 AD3d 831 ; People v Bacquie , 154 AD3d 648, 649 ; People v Brock , 107 AD3d 1025, 1026-1027 ; People v Collins , 105 AD3d 1378, 1379 ).

2017Thus, contrary to the defendant’s contention, and to our dissenting colleague’s conclusion, the police lawfully stopped the defendant’s car due to an apparent violation of Vehicle and Traffic Law § 375 (12-a) (b) (see People v Brock, 107 AD3d at 1026-1027 ; People v Collins, 105 AD3d at 1379 ; People v Hawkins, 45 AD3d at 991 ; People v McKane, 267 AD2d at 253 ).

22017–2020
People v. Davis green
nyappdiv · 1995
2 sentences

2018The credible evidence at the hearing established that police officers properly stopped the vehicle in which the defendant was riding based on an apparent violation of Vehicle and Traffic Law § 375(12-a)(b) ( see People v Estrella, 10 NY3d 945, 946 ; People v McKane, 267 AD2d 253 ; People v Edwards, 222 AD2d 603, 604 ).

1999Contrary to the defendant’s contention, the police properly stopped his car due to an apparent violation of Vehicle and Traffic Law § 375 (12-a) (b) (2) (see, People v Henry, 258 AD2d 473 ; People v Alcide, 252 AD2d 591 ; People v Dougherty, 251 AD2d 344, 345 ; People v Edwards, 222 AD2d 603 ; People v McGriff, 219 AD2d 829 ).

21999–2018
People v. McKane neutral
nyappdiv · 1999
2 sentences

2018The credible evidence at the hearing established that police officers properly stopped the vehicle in which the defendant was riding based on an apparent violation of Vehicle and Traffic Law § 375(12-a)(b) ( see People v Estrella, 10 NY3d 945, 946 ; People v McKane, 267 AD2d 253 ; People v Edwards, 222 AD2d 603, 604 ).

2017Thus, contrary to the defendant’s contention, and to our dissenting colleague’s conclusion, the police lawfully stopped the defendant’s car due to an apparent violation of Vehicle and Traffic Law § 375 (12-a) (b) (see People v Brock, 107 AD3d at 1026-1027 ; People v Collins, 105 AD3d at 1379 ; People v Hawkins, 45 AD3d at 991 ; People v McKane, 267 AD2d at 253 ).

22017–2018
Fred Smith Plumbing and Heating Co. v. Christensen green
nyappdiv · 1997
2 sentences

2013To the extent that the breach of contract defense may amount to a viable claim, it may be asserted in a separate action (see SCP [Bermuda], 242 AD2d at 430 ; Malsin v Stockman, 265 AD2d 533 [2d Dept 1999]).

2013To the extent that the breach of contract defense may amount to a viable claim, it may be asserted in a separate action (see SCP [Bermuda], 242 AD2d at 430 ; Malsin v Stockman, 265 AD2d 533 [2d Dept 1999]).

22013–2013
Malsin v. Stockman green
nyappdiv · 1999
2 sentences

2013To the extent that the breach of contract defense may amount to a viable claim, it may be asserted in a separate action (see SCP [Bermuda], 242 AD2d at 430 ; Malsin v Stockman, 265 AD2d 533 [2d Dept 1999]).

2013To the extent that the breach of contract defense may amount to a viable claim, it may be asserted in a separate action (see SCP [Bermuda], 242 AD2d at 430 ; Malsin v Stockman, 265 AD2d 533 [2d Dept 1999]).

22013–2013
Welch v. Scheinfeld green
nyappdiv · 2005
1 sentence

2026The doctrine of apparent/ostensible agency requires proof of "words or conduct by the hospital" giving rise to a reasonable belief that the physician possessed authority to act on behalf of the hospital, and reasonable reliance by the patient on that perceived relationship (Pratt v Haber, 105 AD3d 429, 429 [1st Dept 2013]; Welch, 21 AD3d at 807 ).

12026–2026
Hill v. St. Clare's Hospital green
ny · 1986
1 sentence

2026While ostensible agency may be viable where a patient seeks care from a facility rather than from a particular physician (Hill, 67 NY2d at 80 -81 ), the relevant inquiry is fact-specific and depends on the "attendant circumstances." Here, NYPH proffers deposition testimony and documentary evidence demonstrating that plaintiff understood the relevant distinction: plaintiff presented to the NYPH emergency department, but awaited a specialist identified as Dr. Lorich; plaintiff opted to wait for Dr. Lori ch because of the surgeon's reputation; and, critically, following discharge plaintiff contin

12026–2026
People v. Davis green
nyappdiv · 2006
1 sentence

2025Once the defendant admitted to having both a gun and drugs on his person, the police recovery of these items from the defendant's person was justified as a search incident to lawful arrest ( see People v Davis , 32 AD3d 445 ).

12025–2025
People v. Mack green
nyappdiv · 2008
1 sentence

2025Here, the police conduct was justified in light of the defendant's apparent violation of Code of the Village of Hempstead § 95-14, i.e., the Village of Hempstead's open-container law, and the defendant's conduct while interacting with the police ( see People v Mack , 49 AD3d 1291, 1291-1292 ; People v Bothwell , 261 AD2d 232, 234-235 ; see also People v Mitchell , 148 AD3d 730, 731 ; People v Pace , 143 AD3d 1286, 1287 ).

12025–2025
People v. Bothwell green
nyappdiv · 1999
1 sentence

2025Here, the police conduct was justified in light of the defendant's apparent violation of Code of the Village of Hempstead § 95-14, i.e., the Village of Hempstead's open-container law, and the defendant's conduct while interacting with the police ( see People v Mack , 49 AD3d 1291, 1291-1292 ; People v Bothwell , 261 AD2d 232, 234-235 ; see also People v Mitchell , 148 AD3d 730, 731 ; People v Pace , 143 AD3d 1286, 1287 ).

12025–2025
People v. Newton green
nyappdiv · 2016
1 sentence

2025Here, the police conduct was justified in light of the defendant's apparent violation of Code of the Village of Hempstead § 95-14, i.e., the Village of Hempstead's open-container law, and the defendant's conduct while interacting with the police ( see People v Mack , 49 AD3d 1291, 1291-1292 ; People v Bothwell , 261 AD2d 232, 234-235 ; see also People v Mitchell , 148 AD3d 730, 731 ; People v Pace , 143 AD3d 1286, 1287 ).

12025–2025
People v. Fagan green
nyappdiv · 2012
1 sentence

2022Thus, automobile stops are lawful when based on probable cause that a driver has committed a traffic violation ( People v Robinson , 97 NY2d 341, 349-350 [2001]). [2] Contrary to defendant's contention, the credible evidence at the Mapp / Dunaway hearing, where the detective testified{**78 Misc 3d at 6} that he stopped defendant's vehicle for having "excessively tinted windows," was sufficient to establish that the detective had probable cause to lawfully stop the "vehicle due to an apparent violation of Vehicle and Traffic Law § 375 (12-a) (b) (2)" ( People v Rowe , 189 AD3d 894 , 895 [2d Dep

12022–2022
People v. Rowe green
nyappdiv · 2020
1 sentence

2022Thus, automobile stops are lawful when based on probable cause that a driver has committed a traffic violation ( People v Robinson , 97 NY2d 341, 349-350 [2001]). [2] Contrary to defendant's contention, the credible evidence at the Mapp / Dunaway hearing, where the detective testified{**78 Misc 3d at 6} that he stopped defendant's vehicle for having "excessively tinted windows," was sufficient to establish that the detective had probable cause to lawfully stop the "vehicle due to an apparent violation of Vehicle and Traffic Law § 375 (12-a) (b) (2)" ( People v Rowe , 189 AD3d 894 , 895 [2d Dep

12022–2022
People v. Nektalov (Samual) yellow
nyappterm · 2022
1 sentence

2022Thus, automobile stops are lawful when based on probable cause that a driver has committed a traffic violation ( People v Robinson , 97 NY2d 341, 349-350 [2001]). [2] Contrary to defendant's contention, the credible evidence at the Mapp / Dunaway hearing, where the detective testified{**78 Misc 3d at 6} that he stopped defendant's vehicle for having "excessively tinted windows," was sufficient to establish that the detective had probable cause to lawfully stop the "vehicle due to an apparent violation of Vehicle and Traffic Law § 375 (12-a) (b) (2)" ( People v Rowe , 189 AD3d 894 , 895 [2d Dep

12022–2022
People v. Foster green
nyappdiv · 2017
1 sentence

2020The officers had the right to request that the defendant produce his license and registration ( see People v Foster , 153 AD3d 853, 854 ; People v Graham , 54 AD3d 1056, 1058 ).

12020–2020
People v. Gaskin green
nyappdiv · 2008
1 sentence

2020The officers had the right to request that the defendant produce his license and registration ( see People v Foster , 153 AD3d 853, 854 ; People v Graham , 54 AD3d 1056, 1058 ).

12020–2020
People v. Bacquie green
nyappdiv · 2017
1 sentence

2020The credible evidence at the hearing established [*2]that the police officers lawfully stopped the defendant's vehicle due to an apparent violation of Vehicle and Traffic Law § 375(12-a)(b)(2) ( see People v Vanderpool , 157 AD3d 831 ; People v Bacquie , 154 AD3d 648, 649 ; People v Brock , 107 AD3d 1025, 1026-1027 ; People v Collins , 105 AD3d 1378, 1379 ).

12020–2020
People v. Omowale green
ny · 2011
1 sentence

2019The police had, at least, an objective credible reason to approach defendant's stationary vehicle and ask for basic identification information, since the vehicle was double-parked, which constituted a traffic infraction ( see People v Omowale , 83 AD3d 614, 618 [2011], affd 18 NY3d 825 [2011]; People v Citron , 255 AD2d 452 [1998], lv denied 92 NY2d 1030 [1998]) and had a piece of cardboard with handwritten numbers and letters instead of a rear license plate, an apparent violation of Vehicle and Traffic Law § 402(1)(a) ( see People v Ocasio , 85 NY2d 982, 984 [1995] ; People v Thomas , 19 AD3d

12019–2019
People v. Stubblefield green
ny · 2005
12019–2019
People v. Citron neutral
nyappdiv · 1998
1 sentence

2019The police had, at least, an objective credible reason to approach defendant's stationary vehicle and ask for basic identification information, since the vehicle was double-parked, which constituted a traffic infraction ( see People v Omowale , 83 AD3d 614, 618 [2011], affd 18 NY3d 825 [2011]; People v Citron , 255 AD2d 452 [1998], lv denied 92 NY2d 1030 [1998]) and had a piece of cardboard with handwritten numbers and letters instead of a rear license plate, an apparent violation of Vehicle and Traffic Law § 402(1)(a) ( see People v Ocasio , 85 NY2d 982, 984 [1995] ; People v Thomas , 19 AD3d

12019–2019
People v. Estrella green
ny · 2008
12018–2018
People v. Hawkins green
nyappdiv · 2007
12017–2017
Jennings v. Lippman neutral
nyappdiv · 2003
12011–2011
Mulcahy v. Mulcahy green
nyappdiv · 2001
12005–2005
In re John G. green
nyappdiv · 1982
12004–2004
O'Connor v. Alfano green
nyappdiv · 1983
12004–2004
Mahoney v. Jackson's Marina, Inc. neutral
nyappdiv · 2003
12004–2004
People v. Tutt green
nyappdiv · 1993
11999–1999
People v. McGriff green
nyappdiv · 1995
11999–1999
People v. Jackson green
nyappdiv · 1997
11999–1999
People v. Dougherty green
nyappdiv · 1998
11999–1999
People v. Alcide neutral
nyappdiv · 1998
11999–1999
People v. Sira neutral
nyappdiv · 1998
11999–1999
MATTER OF TROPEA v. Tropea green
ny · 1996
11998–1998
Ronald FF. v. Cindy GG. green
ny · 1987
11998–1998
Chang v. Chang green
nyappdiv · 1993
11997–1997
Miller v. Lines green
nyappdiv · 1994
11997–1997
People v. Veloz neutral
nyappdiv · 1991
11995–1995
People v. Diaz green
nyappdiv · 1993
11995–1995
Pennsylvania v. Mimms green
scotus · 1977
11995–1995

Where else courts name it

CA 89 (1877–2026) NY 59 (1890–2026) IL 37 (1889–2024) PA 31 (1834–2025) TX 27 (1917–2026) IN 26 (1881–2012) MI 23 (1898–2021) MO 22 (1901–2019) MN 22 (1890–2016) NC 19 (1909–2022) OR 18 (1902–2021) MA 17 (1931–2025) FL 17 (1937–2019) OH 16 (1926–2025) GA 16 (1917–2023) UT 15 (1888–2024) KS 14 (1882–2014) MD 14 (1914–2007) OK 13 (1912–2009) IA 13 (1910–2020) WV 11 (1887–2017) NJ 10 (1959–2025) CT 10 (1905–2007) CO 10 (1915–2025) MS 10 (1845–2020) AL 9 (1910–2026) KY 8 (1928–2025) AR 8 (1923–2025) NM 7 (1969–2022) DC 7 (1978–2025) WI 6 (1910–2008) WA 6 (1920–2001) VA 5 (1922–2026) SD 5 (1913–2014) AK 4 (1979–2023) AZ 4 (1982–2025) LA 4 (1961–2017) ID 4 (1969–2018) VT 4 (1977–2021) TN 4 (1927–2015) HI 3 (1908–2006) ME 3 (2009–2017) NE 3 (1907–1986) ND 3 (1979–1989) SC 3 (1958–2013) NH 2 (1838–2025) MT 2 (1915–1922)

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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