Bottini v. Sadore Management Corp.’s Empirical Analysis

Citation profile

15 federal appellate · 4 district · 1 state decisions

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 38 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “The jurisdiction of city courts is set forth in N.Y. Judiciary Law, Uniform City Court Act §§ 201-213 (McKinney 1984). Under the statute, city courts are courts of limited jurisdiction. Jurisdiction includes, for example, recovery of money up to a stated amount or chattels or summary proceedings to recover possession of real property located within the city limits. The Yonkers City Court plainly lacked jurisdiction to hear a Title VII employment discrimination claim. While Sadore argues that the discrimination allegations were adjudicated as part of the holdover proceeding, nothing in that record indicates the parties submitted any evidence on this issue. The City Court’s decision focused primarily on the merits of the holdover proceeding. It found merely that Bottini’s discharge was lawful, presumably because Bottini had challenged his eviction by claiming that his discharge from employment was unlawful. Inasmuch as the land lord-tenant city court had limited jurisdiction, it was not a competent or appropriate tribunal to hear Bottini’s allegations of religious discrimination against his employer[-landlord]. Since Bottini did not have a full and fair opportunity to litigate his claim in the Yonkers City Court, its judgment should not bar him from bringing his Title VII claim in federal court.”

   1 later decision quote this exact passage · from the majority
   e.g. Glover v. Jones

2. “[Sjince the Title VII claim was outside the scope of the arbitration proceeding, it was a fortiori beyond the scope of the Article 75 proceeding brought to enforce the arbitrator’s award. Thus, the prior state-court proceeding and the present federal-court proceeding do not involve the same causes of action. Second, inasmuch as the New York court’s review in the Article 75 proceeding was narrowly limited, it lacked the power to entertain the discrimination claim that [the plaintiff] now asserts. Therefore, we conclude that the prior Article 75 proceeding in state court does not preclude plaintiff from pursuing his federal claim.”

   1 later decision quote this exact passage · from the majority
   e.g. 809 F. Supp. 208 - Sewell v. New York City Transit Authority