approximation doctrine (New York) · Go Syfert
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approximation doctrine in New York

7 New York opinions name it 4 courts 1944–2002 0 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 (3)

CaseFollowedCited
Sherman v. Richmond Hose Co. No. 2green
ny · 1921 · cited in 1 New York opinions naming this issue, 1986–1986
1 sentence

1986B The common-law cy pres doctrine, or "ancient doctrine of approximation” as it has been termed (Greenfield, Practice Commentary, McKinney’s Cons Laws of NY, Book 17B, EPTL 8-1.1, 1986 Cum Ann Pocket Part, p 175; see, Williams v Williams, 8 NY 525 ), embodies the English concept that when a donor parts with his property for a charitable purpose it shall be forever devoted to that purpose, whether or not the particular donee continues to exist (Sherman v Richmond Hose Co., 230 NY 462 ).

11
In re the Estate of Goehringergreen
nysurct · 1972 · cited in 1 New York opinions naming this issue, 1986–1986
1 sentence

1986If the donee ceases to exist, the property may be devoted to a kindred charity; one that is, "as near as may be” to the charity contemplated by the donor (id.; see also, Matter of Goehringer, 69 Misc 2d 145, 146-147 ; Restatement [Second] of Trusts § 399 comment a, at 297-298).

11
Williams v. . Williamsgreen
ny · 1853 · cited in 1 New York opinions naming this issue, 1986–1986
1 sentence

1986B The common-law cy pres doctrine, or "ancient doctrine of approximation” as it has been termed (Greenfield, Practice Commentary, McKinney’s Cons Laws of NY, Book 17B, EPTL 8-1.1, 1986 Cum Ann Pocket Part, p 175; see, Williams v Williams, 8 NY 525 ), embodies the English concept that when a donor parts with his property for a charitable purpose it shall be forever devoted to that purpose, whether or not the particular donee continues to exist (Sherman v Richmond Hose Co., 230 NY 462 ).

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 (11)

CaseCitedYears
Lutheran Hospital of Manhattan v. Goldstein neutral
nysupct · 1944
2 sentences

1970(Camp v. Presbyterian Soc. of Sackets Harbor, 105 Misc. 139 ; Stevens v. Smith, 134 Me. 175 ; Thatcher v. Lewis, 335 Mo. 1130 ; Matter of Milne, 230 La. 729 .) In Lutheran Hosp. of Manhattan v. Goldstein ( 182 Misc. 913, 917 ) the court said: “ It is well-established law that cy pres is a doctrine of approximation; that it is basically a rule of judicial construction; that its design and purpose are to aid the court to ascertain and carry out, as nearly as may be, the intention of the donor.” This court does, therefore, find, determine and conclude that the'word “ orphans ” as used by the dece

1958In Lutheran Hosp. v. Goldstein ( 182 Misc. 913 ), it was held that cy pres should not be carried to such an extent that the deviation will destroy the testamentary intention; that it is a doctrine of approximation; is basically a rule of judicial construction; its design and purpose is to aid the court to ascertain and carry out as nearly as may be, the intention of the donor.

31956–1970
People v. Cassidy green
ny · 1976
1 sentence

2002The merger doctrine precludes conviction for kidnapping based on acts which are “so much the part of another substantive crime that the substantive crime could not have been committed without such acts and that independent criminal responsibility may not fairly be attributed to them.” (People v Gonzalez, supra, 80 NY2d 146, 153 , quoting People v Cassidy, 40 NY2d 763, 767 ; see also, People v Cain, 76 NY2d. 119, 125.) Thus, where the abduction and underlying crime are discrete, a kidnapping conviction will be sustained.

12002–2002
People v. Warren green
ny · 1985
1 sentence

2002(See, People v Bracey, 41 NY2d 296 , 300; People v Warren, 66 NY2d 831, 832 ; see also, Penal Law § 110.00.) Finally, it should be noted, defendant declined, for strategic reasons, to present a defense of intoxication and should therefore not be permitted to raise the approximation of such a defense on appeal. 2 Nor is there any merit to defendant’s argument that the merger doctrine mandates dismissal of the conviction for attempted kidnapping.

12002–2002
People v. Gonzalez green
ny · 1992
2 sentences

2002The merger doctrine precludes conviction for kidnapping based on acts which are “so much the part of another substantive crime that the substantive crime could not have been committed without such acts and that independent criminal responsibility may not fairly be attributed to them.” (People v Gonzalez, supra, 80 NY2d 146, 153 , quoting People v Cassidy, 40 NY2d 763, 767 ; see also, People v Cain, 76 NY2d. 119, 125.) Thus, where the abduction and underlying crime are discrete, a kidnapping conviction will be sustained.

2002The merger doctrine precludes conviction for kidnapping based on acts which are “so much the part of another substantive crime that the substantive crime could not have been committed without such acts and that independent criminal responsibility may not fairly be attributed to them.” (People v Gonzalez, supra, 80 NY2d 146, 153 , quoting People v Cassidy, 40 NY2d 763, 767 ; see also, People v Cain, 76 NY2d. 119, 125.) Thus, where the abduction and underlying crime are discrete, a kidnapping conviction will be sustained.

12002–2002
In Re Multiple Sclerosis Service Organization of New York, Inc. green
ny · 1986
1 sentence

1991Org., 68 NY2d 32, 41 ).

11991–1991
Camp v. Presbyterian Society of Sackets Harbor green
nysupct · 1918
1 sentence

1970(Camp v. Presbyterian Soc. of Sackets Harbor, 105 Misc. 139 ; Stevens v. Smith, 134 Me. 175 ; Thatcher v. Lewis, 335 Mo. 1130 ; Matter of Milne, 230 La. 729 .) In Lutheran Hosp. of Manhattan v. Goldstein ( 182 Misc. 913, 917 ) the court said: “ It is well-established law that cy pres is a doctrine of approximation; that it is basically a rule of judicial construction; that its design and purpose are to aid the court to ascertain and carry out, as nearly as may be, the intention of the donor.” This court does, therefore, find, determine and conclude that the'word “ orphans ” as used by the dece

11970–1970
Thatcher v. St. Louis green
· 1934
1 sentence

1970(Camp v. Presbyterian Soc. of Sackets Harbor, 105 Misc. 139 ; Stevens v. Smith, 134 Me. 175 ; Thatcher v. Lewis, 335 Mo. 1130 ; Matter of Milne, 230 La. 729 .) In Lutheran Hosp. of Manhattan v. Goldstein ( 182 Misc. 913, 917 ) the court said: “ It is well-established law that cy pres is a doctrine of approximation; that it is basically a rule of judicial construction; that its design and purpose are to aid the court to ascertain and carry out, as nearly as may be, the intention of the donor.” This court does, therefore, find, determine and conclude that the'word “ orphans ” as used by the dece

11970–1970
In Re Succession of Milne green
la · 1956
1 sentence

1970(Camp v. Presbyterian Soc. of Sackets Harbor, 105 Misc. 139 ; Stevens v. Smith, 134 Me. 175 ; Thatcher v. Lewis, 335 Mo. 1130 ; Matter of Milne, 230 La. 729 .) In Lutheran Hosp. of Manhattan v. Goldstein ( 182 Misc. 913, 917 ) the court said: “ It is well-established law that cy pres is a doctrine of approximation; that it is basically a rule of judicial construction; that its design and purpose are to aid the court to ascertain and carry out, as nearly as may be, the intention of the donor.” This court does, therefore, find, determine and conclude that the'word “ orphans ” as used by the dece

11970–1970
Stevens v. Smith neutral
me · 1936
1 sentence

1970(Camp v. Presbyterian Soc. of Sackets Harbor, 105 Misc. 139 ; Stevens v. Smith, 134 Me. 175 ; Thatcher v. Lewis, 335 Mo. 1130 ; Matter of Milne, 230 La. 729 .) In Lutheran Hosp. of Manhattan v. Goldstein ( 182 Misc. 913, 917 ) the court said: “ It is well-established law that cy pres is a doctrine of approximation; that it is basically a rule of judicial construction; that its design and purpose are to aid the court to ascertain and carry out, as nearly as may be, the intention of the donor.” This court does, therefore, find, determine and conclude that the'word “ orphans ” as used by the dece

11970–1970
In re the Estate Meyers neutral
nysurct · 1938
1 sentence

1944Guild for Jewish Blind, 252 App. Div. 493 ; Matter of Meyers, 166 Misc. 712 .) It is well-established law that cy pres is a doctrine of approximation ; that it is basically a rule of judicial construction; that its design and purpose are to aid the court to ascertain and carry out, as nearly as may be, the intention of the donor. “ The cy pres doctrine can properly be applied only where it is or has become impossible beneficially to apply the property left by. the founder or donor in the exact way in which he has dictated it to be applied, and it can only be applied beneficially to similar pur

11944–1944
Prudential Insurance Co. of America v. New York Guild for the Jewish Blind neutral
nyappdiv · 1937
1 sentence

1944Guild for Jewish Blind, 252 App. Div. 493 ; Matter of Meyers, 166 Misc. 712 .) It is well-established law that cy pres is a doctrine of approximation ; that it is basically a rule of judicial construction; that its design and purpose are to aid the court to ascertain and carry out, as nearly as may be, the intention of the donor. “ The cy pres doctrine can properly be applied only where it is or has become impossible beneficially to apply the property left by. the founder or donor in the exact way in which he has dictated it to be applied, and it can only be applied beneficially to similar pur

11944–1944

Where else courts name it

CT 17 (1898–2023) IA 15 (2008–2026) PA 9 (1923–2024) NY 7 (1944–2002) IN 3 (1881–1983) LA 3 (1913–1985) MS 2 (1977–2009) WA 2 (1953–1960)

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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