ARTIFICIAL INTELLIGENCE [AI] IS NOT USED, IN WHOLE OR IN PART, IN PREPARING NYPPL SUMMARIES OF JUDICIAL AND QUASI-JUDICIAL DECISIONS

Jun 24, 2025

A screenshot from the agency's website introduced into evidence by the Plaintiff in the course of a CPLR Article 78 proceeding

Plaintiff, an armored transportation company transporting cash and currencies, appealed the New York City Office of Administrative Trials & Hearings [OATH] decision finding Plaintiff guilty of violating §24-163 Administrative Code of City of NY by reason of its employees allowing "the engine of a motor vehicle ... to idle" in violation of §24-163 which states that a "'processing device shall not include a heater or air conditioner operated for cabin comfort".

In the words of the Appellate Division, the question here is whether an armored truck while making a delivery is considered a "processing device." 

The Court noted that:

1. The Plaintiff's employees "must keep the vehicle's engine running to keep its security system operative, to allow the vehicle to be moved instantly in the event of a robbery, and to ventilate the vehicle since its windows are sealed for security reasons"; 

2. Plaintiff had submitted evidence -- a screenshot from the New York City's Department of Environmental Protection' [DEP] website -- indicating that "armored trucks" are described as "an activity classified as process"; 

3. DEP had sent Plaintiff an email indicating that it's armored vehicles were not subject to the prohibition set out in §24-163; and 

4. DEP had advised Plaintiff that DEP had a  protocol in place indicating that in the event "the work being performed is directly related to the reason the vehicle is idling, the inspector is not to issue the violation." 

Finding OATH's determination to be arbitrary and capricious, the Appellate Division granted Plaintiff's Article 78 petition, unanimously reversed OATH's decision, and annulled OATH's determination

Click HERE to access the Appellate Division's decision posted on the Internet. 


NYPPL Publisher Harvey Randall served as Principal Attorney, New York State Department of Civil Service; Director of Personnel, SUNY Central Administration; Director of Research, Governor’s Office of Employee Relations; and Staff Judge Advocate General, New York Guard. Consistent with the Declaration of Principles jointly adopted by a Committee of the American Bar Association and a Committee of Publishers and Associations, the material posted to this blog is presented with the understanding that neither the publisher nor NYPPL and, or, its staff and contributors are providing legal advice to the reader and in the event legal or other expert assistance is needed, the reader is urged to seek such advice from a knowledgeable professional.

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