plaintiff relying upon exception (New York) · Go Syfert
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plaintiff relying upon exception in New York

6 New York opinions name it 2 courts 1981–2022 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 (5)

CaseFollowedCited
Connell v. Haydengreen
nyappdiv · 1981 · cited in 3 New York opinions naming this issue, 1984–2022
2 sentences

2022Connell v Hayden , 83 AD2d 30, 39 [once a defendant established, prima facie, that an action was untimely, "a plaintiff relying upon an exception thereto has the burden of proving that he [or she] comes within the exception"]; Doyon v Bascom , 38 AD2d 645 ["While the burden of proving the affirmative defense of the Statute of Limitations rests on the party invoking it, a defendant asserting the statute need not negate any exceptions contained therein, the burden resting upon plaintiffs to aver facts showing the case at hand falls within such exceptions"]; Beattys v Straiton , 142 App Div 369,

2020"However, a plaintiff relying upon an exception thereto has the burden of proving that [it] comes within the exception" ( id. at 39 ). "[T]he Statute of Limitations is generally viewed as a personal defense" ( John J.

13
Beattys v. Straitongreen
· 1911 · cited in 2 New York opinions naming this issue, 1981–2022
2 sentences

2022Connell v Hayden , 83 AD2d 30, 39 [once a defendant established, prima facie, that an action was untimely, "a plaintiff relying upon an exception thereto has the burden of proving that he [or she] comes within the exception"]; Doyon v Bascom , 38 AD2d 645 ["While the burden of proving the affirmative defense of the Statute of Limitations rests on the party invoking it, a defendant asserting the statute need not negate any exceptions contained therein, the burden resting upon plaintiffs to aver facts showing the case at hand falls within such exceptions"]; Beattys v Straiton , 142 App Div 369,

1981However, a plaintiff relying upon an exception thereto has the burden of proving that he comes within the exception (Beattys v Straiton, 142 App Div 369, 375 ; Murphy v Walsh, 113 App Div 428 ).

12
Groninger v. Village of Mamaroneckgreen
ny · 2011 · cited in 1 New York opinions naming this issue, 2022–2022
1 sentence

2022The Court of Appeals has indicated that the same principle applies in the prior written notice context: "Where the City establishes that it lacked prior written notice under [Administrative Code § 7-201(c)(2)], the burden shifts to the plaintiff to demonstrate the applicability of one of two recognized exceptions to [that defense]" ( Yarborough v City of New York , 10 NY3d at 728 ; see Groninger v Village of Mamaroneck , 17 NY3d 125 ).

11
Lau v. Kygreen
nyappdiv · 2009 · cited in 1 New York opinions naming this issue, 2014–2014
1 sentence

2014Co., 7 NY3d at 209 ; Bunting v Haynes, 104 AD3d at 715 ; Lau v Ky, 63 AD3d 801, 801 [2009]).

11
Terry Clark v. Robert J. Tansy, Warden Attorney General for the State of New Mexicogreen
ca10 · 1993 · cited in 1 New York opinions naming this issue, 2007–2007
1 sentence

2007Co., 207 F2d 334, 336 [7th Cir 1953], cert denied 347 US 913 [1954]), but rather, “Dismissal under Rule 41 (a)(2) is within the sound discretion of the court” (Clark v Tansy, 13 F3d 1407, 1411 [10th Cir 1993]).

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 (7)

CaseCitedYears
Flanagan v. Nyquist green
nyappdiv · 1971
1 sentence

2022Connell v Hayden , 83 AD2d 30, 39 [once a defendant established, prima facie, that an action was untimely, "a plaintiff relying upon an exception thereto has the burden of proving that he [or she] comes within the exception"]; Doyon v Bascom , 38 AD2d 645 ["While the burden of proving the affirmative defense of the Statute of Limitations rests on the party invoking it, a defendant asserting the statute need not negate any exceptions contained therein, the burden resting upon plaintiffs to aver facts showing the case at hand falls within such exceptions"]; Beattys v Straiton , 142 App Div 369,

12022–2022
Yarborough v. City of New York green
ny · 2008
1 sentence

2022The Court of Appeals has indicated that the same principle applies in the prior written notice context: "Where the City establishes that it lacked prior written notice under [Administrative Code § 7-201(c)(2)], the burden shifts to the plaintiff to demonstrate the applicability of one of two recognized exceptions to [that defense]" ( Yarborough v City of New York , 10 NY3d at 728 ; see Groninger v Village of Mamaroneck , 17 NY3d 125 ).

12022–2022
John J. Kassner & Co. v. City of New York green
ny · 1979
2 sentences

2020Kassner & Co. v City of New York , 46 NY2d 544, 550 ). "[A]s a general rule a party who has not raised the Statute of Limitations as a defense in the answer or by a motion to dismiss is held to have waived it" ( id. at 552 ; see CPLR 3211[e]; see also Weinstein-Korn-Miller, NY Civ Prac CPLR ¶ 201.11 [2020]).

2020Kassner & Co. v City of New York , 46 NY2d 544, 550 ). "[A]s a general rule a party who has not raised the Statute of Limitations as a defense in the answer or by a motion to dismiss is held to have waived it" ( id. at 552 ; see CPLR 3211[e]; see also Weinstein-Korn-Miller, NY Civ Prac CPLR ¶ 201.11 [2020]).

12020–2020
Bunting v. Haynes green
nyappdiv · 2013
1 sentence

2014Co., 7 NY3d at 209 ; Bunting v Haynes, 104 AD3d at 715 ; Lau v Ky, 63 AD3d 801, 801 [2009]).

12014–2014
Morejon v. Rais Construction Co. green
ny · 2006
1 sentence

2014Co., 7 NY3d at 209 ; Bunting v Haynes, 104 AD3d at 715 ; Lau v Ky, 63 AD3d 801, 801 [2009]).

12014–2014
Cincinnati Butchers' Supply Co. v. Pfeifer green
scotus · 1954
1 sentence

2007Co., 207 F2d 334, 336 [7th Cir 1953], cert denied 347 US 913 [1954]), but rather, “Dismissal under Rule 41 (a)(2) is within the sound discretion of the court” (Clark v Tansy, 13 F3d 1407, 1411 [10th Cir 1993]).

12007–2007
Murphy v. Walsh neutral
· 1906
1 sentence

1981However, a plaintiff relying upon an exception thereto has the burden of proving that he comes within the exception (Beattys v Straiton, 142 App Div 369, 375 ; Murphy v Walsh, 113 App Div 428 ).

11981–1981

Where else courts name it

NY 6 (1981–2022) MI 3 (1975–1987) IN 3 (1994–2019) LA 2 (1961–1962)

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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