New York Consolidated Laws

N.Y. Social Services Law § 420 (2026)

Penalties for failure to report

✓ current as of May 2026

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§ 420.  Penalties for failure to report.  1.  Any person, official or
institution required by this title to report a case of suspected child
abuse or maltreatment who willfully fails to do so shall be guilty of a
class A misdemeanor.
  2.  Any person, official or institution required by this title to
report a case of suspected child abuse or maltreatment who knowingly and
willfully fails to do so shall be civilly liable for the damages
proximately caused by such failure.

Notes of Decisions

Cited in 34 cases (13 in the last 5 years), 1987–2025 · leading case: Weisbrod-Moore v. Cayuga Cnty., 2025 NY Slip Op 00903 (NY 2025).

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Weisbrod-Moore v. Cayuga Cnty., 2025 NY Slip Op 00903 (NY 2025). · cites it 6× “Critically, the legislature saw fit to create a private right of action under Social Services Law § 420, which "provides for criminal and civil liability for the willful failure of persons, officials or institutions required by title 6 to report cases of 'suspected child abuse…”

Lara v. City of New York, 187 Misc. 2d 882 (N.Y. Sup. Ct. 2001). · cites it 6× “Both sentences of Social Services Law § 419 must be read in pari materia with Social Services Law § 420 and in context as component parts of Social Services Law, article 6, title 6 (Child Protective Services).”

BL DOE 3 v. Female Academy of the Sacred Heart, 2021 NY Slip Op 06480 (N.Y. App. Div. 2021). · cites it 2× “Here, there is nothing in the language of Social Services Law § 420 (2), which provides a private right of action against a mandated reporter who willfully fails to fulfill his or her statutory reporting obligation, that expresses a legislative intent to curb or override…”

Grant v. Cuomo, 130 A.D.2d 154 (N.Y. App. Div. 1987). · cites it 2× “The willful failure to make a report by persons legally required to do so is a class A misdemeanor and may give rise to civil liability as well (Social Services Law § 420). As noted above, all social services workers are required to report cases "when they have reasonable cause…”

Kimberly S. M. v. Bradford Cent. Sch., 226 A.D.2d 85 (N.Y. App. Div. 1996). · cites it 2× “Plaintiffs, Kimberly’s parents, commenced this action pursuant to Social Services Law § 420 (2), seeking to recover damages for the psychological and emotional trauma Kimberly allegedly suffered between May 1993 and May 1994 as the result of the teacher’s failure to report a…”

Dolgas v. Wales, 2023 NY Slip Op 01830 (N.Y. App. Div. 2023). “Civil liability may be imposed upon these individuals who knowingly and willfully fail to make the requisite report ( see Social Services Law § 420 [2]). That said, for purposes of Social Services Law § 413, an "abused child" is one who is [*5]abused by a "parent or other person…”

Uhr v. East Greenbush Cent. Sch. Dist., 720 N.E.2d 886 (NY 1999). “, Social Services Law § 420 [2]; General Obligations Law § 11-100 [1]; § 11-101 [1]), there is no need for further analysis.”

Storck v. Suffolk Cnty. Dep't of Soc. Servs., 62 F. Supp. 2d 927 (E.D.N.Y 1999). “N.Y. Social Serv.L. § 420 . The CPSA has a broad immunity provision.”

Visiko v. Fleming, 2021 NY Slip Op 06484 (N.Y. App. Div. 2021). “Finally, for the reasons stated above in connection with plaintiff's common-law failure to report cause of action, we reject defendant's contention that plaintiff's statutory failure to report cause of action should have been dismissed against defendant for failure to state a…”

Hanson v. Hicksville Union Free Sch. Dist., 2022 NY Slip Op 05519 (N.Y. App. Div. 2022). “Social Services Law § 420(2) provides that "[a]ny person, official or institution required by this title to report a case of suspected child abuse or maltreatment who knowingly and willfully fails to do so shall be civilly liable for the damages proximately caused by such…”

Young v. Campbell, 87 A.D.3d 692 (N.Y. App. Div. 2011). · cites it 2× “The second, fourth, and sixth causes of action were, in effect, pursuant to Social Services Law § 420 to recover damages for emotional distress and additional attorneys’ fees the plaintiff allegedly incurred due to the alleged failure of all the defendants, except Martha Carlin,…”

Satler v. Larsen, 131 A.D.2d 125 (N.Y. App. Div. 1987). · cites it 2× “The obligation to report suspected child abuse has been deemed so important that willful failure to comply therewith has been made punishable as a class A misdemeanor (Social Services Law § 420 [1]) and constitutes a ground for the imposition of civil liability (Social Services…”

Show all 34 citing cases →

— N.Y. Social Services Law § 420(2) — 3 cases

Brave v. City of New York, 2023 NY Slip Op 02490 (N.Y. App. Div. 2023).

Zubko-Valva v. The Cnty. of Suffolk (E.D.N.Y 2022).

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