Uniformed Fire Officers Ass'n, Local 854 v. City of New York
Opinion of the Court
Order, Supreme Court, New York County (Arthur F. Engoron, J), entered on or about April 10, 2012, which denied the City’s motion to quash a judicial subpoena, unanimously affirmed, without costs.
The City failed to show that the public interest would be harmed by the disclosure of drafts of a public safety consultant’s
There is no basis for the City’s claim of protection under the so-called “self-critical” privilege. This privilege has never been recognized under New York law, and this case is not the exceptional and compelling case that justifies the judicial creation of a new privilege (see Lamitie v Emerson Elec. Co.— White Rodgers Div., 142 AD2d 293, 298-299 [3d Dept 1988], lv dismissed 74 NY2d 650 [1989]). Concur — Mazzarelli, J.P., Sweeny, Moskowitz, Renwick and Freedman, JJ.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.