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Hybrid Highlights: Avoiding the Pitfalls of a Land Use Litigation Technique

All civil judicial proceedings must be in the form of an action – unless otherwise authorized by statute, i.e. in the form of a special proceeding (see CPLR 103[b]). While most lawsuits are brought solely in the form of...more

Foie Gras Faux Pas: City Runs A-fowl of State Farming Protections

In City of New York v Ball, 2024 NY Slip Op 24179 [Sup Ct, Albany County 2024], the Albany County Supreme Court upheld a determination of the Commissioner (“Commissioner”) of the Department of Agriculture and Markets...more

Friend of the Shawangunks v. Town of Gardiner Planning Board: Litigation Concerning a Popular Outdoor Recreation Area Prompts the...

OVERVIEW - The Shawangunk Ridge is a cluster of bedrock in upstate New York popular for its scenery and outdoor recreation. The Town of Gardiner’s (“Gardiner”) Shawangunk Ridge Protection District (“SRPD”) protects the...more

Fourth Department Frenzy: Reversionary Zoning, Sewer Agreements, Site Plan Review, and Constitutional Rights

In Riedman Acquisitions, LLC v Town Bd. of Town of Mendon, 194 AD3d 1444, 2021 NY Slip Op 02952 [4th Dept 2021], the Appellate Division, Fourth Department, addressed several significant issues concerning land development...more

Sand Mining Hits Rock Bottom: LI’s Local Laws May Prohibit Future Operations

Last month, the Appellate Division, Third Department, held the Mined Land Reclamation Law (“Mining Law”), as amended, does not preempt certain local zoning laws which prohibit mining. Specifically, in Town of Southampton v...more

Second Department Affirms Limits on Site Plan Determinations

This month, in Gershow Recycling of Riverhead v Town of Riverhead, 2021 NY Slip Op 02156 [2d Dept 2021], the Appellate Division, Second Department, affirmed the motion court’s decision granting an Article 78 petition to annul...more

Shinnecock Nation’s Second Sign Sees Renewed State Resistance

Last May, in Commissioner of the State of New York Department of Transportation, et al. v Polite, Index No. 610010/2019, the Suffolk County Supreme Court denied the State’s application for a preliminary injunction to enjoin...more

Amityville Prepares For Production: Avoiding the Horror with Proposed Filming Law

With prospects of featuring its history and architecture on screen, the Village of Amityville (“Amityville“) has been considering adopting a local law to regulate filming and photography for movies, television and...more

Farmingdale To Bring Upper Levels to the Ground Floor: Proposed Amendments to Downtown Zoning

Tonight, the Incorporated Village of Farmingdale (“Farmingdale“) will consider amending its zoning code to expand permitted uses in its Downtown Mixed-Use Zoning District (“Downtown“). The proposed amendments will allow,...more

Flag on the Play for Illegal Procedure: Necessary Parties and the Pitfalls of Nonjoinder

Failure to name a necessary party when challenging a land use determination may result in dismissal, and leave a challenger without further recourse. CPLR 1003 provides that the nonjoinder of a party who should be joined...more

Utilizing CPLR 3102(c) Pre-Action Discovery in the Article 78 Proceedings – Can’t Go Fishin’

Last February, in Dreyer v Stachecki, 2020 NY Slip Op 50134(U), the Suffolk County Supreme Court denied an unopposed motion for pre-action discovery. CPLR Section 3102(c) authorizes disclosure – prior to commencement – to aid...more

“General” Code Provision Saves Dollar Store Endeavor: Superfluous Interpretations Are Not Required

In Cady v Town of Germantown Planning Bd., 2020 NY Slip Op 03440 [3d Dept 2020], the Appellate Division, Third Department, reversed the Columbia County Supreme Court’s judgment annulling site plan approval, and dismissed the...more

How and When to Challenge SEQRA Determinations: Addressing Ripeness and Finality in Article 78 Cases

How and when to challenge multiple municipal actions regarding a single project often perplexes Article 78 litigants. Varying statutes of limitations may apply to actions taken at various stages for one project, and the...more

Court Denies Preliminary Injunction to Enjoin Shinnecock Nation’s Project along Sunrise Highway

Last week, the New York Supreme Court, Suffolk County, denied an application for a preliminary injunction to enjoin the completion, maintenance and operation of two sixty-foot tall electronic billboard-monuments (“Project”)...more

Zoning Boards May Consider the Proposed Use and Purpose When Deciding Area Variance Applications, But Cannot Forget the...

When deciding an area variance application, a zoning board may consider the proposed use of the property and the purpose in seeking the variance. However, the zoning board cannot fail to account for the five-factor test...more

How Executive Order 202.8’s 30-Day “Tolling” Affects Statutes of Limitations in the Article 78 Context

Recent executive and administrative orders carrying-out COVID-19 mitigation and public safety measures will impact litigation within the Article 78 context, specifically the deadlines for commencing a proceeding to challenge...more

Town Takes Trailer: Enforcing Zoning Ordinance against Unresponsive Violators

In Town of Brookhaven v Golemi, 2019 NY Slip Op 51477(U) [Sup Ct, Suffolk County 2019], the Town of Brookhaven (“Brookhaven”) successfully sought and obtained injunctive relief to remove a structure that violated Brookhaven’s...more

Village’s Vitiation of Riparian Rights Survives Initial Challenge

In Akeson v Inc. Vil. of Asharoken, 2019 NY Slip Op 32756(U), Index No. 57/2018 (Sup Ct, Suffolk County 2019), the Supreme Court dismissed a petition challenging the Incorporated Village of Asharoken’s (“Asharoken”) decisions...more

Parking Ticket Fix Earns Counsel Two Years’ Suspension

In Matter of Weissmann, 2019 NY Slip Op 06170 (2d Dep’t 2019), the Special Prosecutor for the Village of Spring Valley Justice Court received a two-year suspension from the practice of law for helping select defendants...more

Short-Term Rental Law Stumbles, But Survives Federal Court Challenge

Earlier this month, a challenge to the Town of Shelter Island (“Shelter Island”) short term rental law ordinance enacted in April 2017, amended May 2019 (“STRL”), came to an end – for now. ...more

The Appellate Division, Third Department, Holds a Brewpub May Be an Accessory Use to a Golf Course

While the Town of Halfmoon (“Town”) in Saratoga County, New York,  may be far from any given reader, the issues in Micklas v. Town of Halfmoon Planning Board, 170 A.D.3d 1483 (3d Dep’t 2019), are close to the heart: whether a...more

Time-Frames for Prosecuting an Article 78 Challenge May Be Shorter Than You Think

In Rimler v. City of New York, 2019 N.Y. Slip Op. 03599 (2d Dept, May 8, 2019), which involved a challenge to the issuance of a negative declaration, the Appellate Division, Second Department, affirmed a judgment of the...more

Zoning Boards Cannot Render Determinations Absent Jurisdiction and Not All Violations of the Open Meetings Law Justify Annulment...

The Appellate Division, Second Department, in Chestnut Ridge Associates, LLC v 30 Sephar Lane, Inc. 169 A.D.3d 995, 2019 N.Y. Slip Op. 01388 [2d Dept 2019], modified a decision of the Supreme Court, Rockland County, which,...more

The Effect or Interpretation of an Ordinance at the Time of Review Applies, Despite Long-Standing Historical Views

In The Committee for Environmentally Sound Development v. Amsterdam Avenue Development Associates, LLC, 2019 WL 1206357, 2019 N.Y. Slip Op. 30621(U), Index No. 153819 (Sup. Ct. New York Co., March 14, 2019)...more

Municipalities Cannot Withhold Permits to Secure Infrastructure and Improvements

In Joy Builders, Inc. v. Town of Clarkstown, 2018 N.Y. Slip Op. 07110, 165 A.D.3d 1084 (2d Dept 2018), a developer (“Developer”), in connection with the development of two subdivisions, challenged a provision of the Town Code...more

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