State of New York Court of Appeals This memorandum is uncorrected and subject to revision before publication in the New York Reports.

No. 8 Suzanne P., &c., Appellant, v. Joint Board of Directors of Erie-Wyoming County Soil Conservation District, &c., et al., Respondents.

William A. Quinlan, for appellant.

Mark P. Della Posta, for respondent Joint Board of Directors of Erie-Wyoming County Soil Conservation District.

Justin L. Hendricks, for respondent Erie County Soil and Water Conservation District.

Breanna C. Reilly, for respondent Wyoming County Soil and Water Conservation District.

Jeremy C. Toth, for respondent County of Erie.

Norman S. Greene, for respondent Town of West Seneca.

Reargument ordered for a future Court session. Acting Chief Judge Cannataro and Judges Rivera, Garcia, Wilson, Singas and Troutman concur.

Decided January 10, 2023