H.F. v. State (2026)

Case details
Full caption
H.F. v. The STATE of New York
Country
United States
Jurisdiction
New York (NY)
Court
New York Court of Appeals
Decided
2026
Disposition
Motion Denied
H.F. v. State, 254 N.Y.S.3d 898 (2026)2026 N.Y. Slip Op. 26040WESTLAW©2026Thomson Reuters. No claim to original U.S. Government Works.1254 N.Y.S.3d 898Court of Claims of New York.H.F., Claimant,v.The STATE of New York, Defendant.Claim No. 144615|Decided on February 10, 2026Editor's Note: This document contains discussion of unverified citations, likely generated by AI tools used by a party orcounsel. These citations are not attributable to the Court. The unverified citations have been preserved as part of the officialrecord, but links are unavailable.Background: Claimant brought action against the State for alleged sexual abuse she suffered while residing at juvenile detentionfacility. The State filed motion for change of venue.Holdings: The Court of Claims, Perer, J., held that:to address conduct by claimant's counsel in citing apparently fictitious cases, and to deter similar future conduct, court wouldstrike counsel's affirmation, in opposition to the State's motion, from the record, andvenue of claimant's claim against the State was proper in the Utica District which encompassed county where facility waslocated.Motion denied.Attorneys and Law FirmsFor Claimant: Law Office of Kenneth M. Mollins, P.C., By: Timothy Manning, Esq.For Defendant: LETITIA JAMES, New York State Attorney General, By: Ramona L. Rabeler, Esq., Assistant Attorney GeneralOpinionAbby R. Perer, J.*899 Claimant H.F. is pursuing a Claim for alleged sexual abuse she suffered while residing at the Taberg Residential Centerfor Girls, located in Taberg, New York, in Oneida County. With her Claim, the Claimant filed and served a summons thatincluded the following language: “[Claimant] designate[s] Nassau County as Place of Trial” (Claim No. 144615 [“Claim”],Summons at p. 1). The Defendant State of New York (“State” or “Defendant”) brings the instant motion to change venue toOneida County. Claimant's counsel responded, relying on apparently fictitious cases to argue venue is proper in Nassau Countybecause, among other reasons, it is where Claimant resides. The State replied, arguing that the Uniform Rules for the Courtof Claims vest the Clerk of Court with the power to designate venue for this Claim. As explained below, because the Claim
H.F. v. State, 254 N.Y.S.3d 898 (2026)2026 N.Y. Slip Op. 26040WESTLAW©2026Thomson Reuters. No claim to original U.S. Government Works.2was originally assigned, and remains assigned, to the Utica District of the Court of Claims, which encompasses Oneida County,the State's motion is denied as moot.Use of Fictitious Cases by Claimant's CounselBefore turning to Defendant's motion, the Court must address Claimant's counsel's use of fictitious case cites in their filing withthis Court. On January 21, 2026, Claimant's counsel, Timothy Manning from the Law Office of Kenneth M. Mollins, P.C., filedan Affirmation in Opposition to Defendant's motion (“Manning Affirmation”). When reviewing the Manning Affirmation, theCourt was unable to locate four Court of Claims cases cited therein. In addition, multiple other authorities cited in the ManningAffirmation did not appear to support the arguments being made, including, inter alia, Court of Claims Act § 9 (2) (which wascited by Mr. Manning for the proposition that venue is proper where a claimant resides, even though the text of the sectionsays nothing about venue or a claimant's residence) and Lepkowski v. State of New York, 1 N.Y.3d 201, 770 N.Y.S.2d 696, 802N.E.2d 1094 (2003). As a result, on January 28, 2025, the Court wrote to Claimant's counsel requesting copies of the four Courtof Claims cases that could not be located. Claimant's counsel failed to respond to that communication.Claimant's counsel's use of apparently fictitious cases is not only a violation of their ethical obligations, but a deeply troublingact of disrespect to their client, opposing counsel, and the court process (see Deutsche Bank Natl. Trust Co. v. LeTennier, –––A.D.3d ––––, 250 N.Y.S.3d 260 [3d Dept. 2026] [“there are many harms associated with the submission of fake cases thatextend beyond merely wasting the time and money of the opposing party, but also in taking up the court's *900 resources toevaluate and resolve the deception”]; Grymes Dev. Co. v. Fodera, 88 Misc.3d 767, 769–70, 773, 245 N.Y.S.3d 863 [Sup. Ct.,Richmond County 2025], citing Rules of Prof Conduct [22 NYCRR 1200.0] rule 3.3 [a] [1] [“At a minimum, a lawyer has anethical obligation and duty to refrain from knowingly make a false statement of fact or law to the Court.”]). “[E]very attorneyhas an ongoing responsibility to review and ensure the accuracy of filings with this and other courts. This includes checkingthat all case law cited in a brief actually exists and supports the points being made” (Augustin v. Formula 3 Brooklyn Inc., 86Misc. 3d 1236[A], 2025 N.Y. Slip Op. 51113[U], *4, 2025 WL 2006010 [Sup. Ct., Kings County 2025] [citation omitted]).To address the conduct by Claimant's counsel, and hopefully deter similar future conduct, the Court will strike the ManningAffirmation from the record and will not consider it for purposes of deciding Defendant's motion.In the event Claimant's counsel utilizes fictitious cases in any other filings before this Court, the Court will, at a minimum, imposeeconomic sanctions and refer counsel to the appropriate attorney grievance committee (see 22 NYCRR 130-1.1; Deutsche BankNatl. Trust Co., ––– A.D.3d ––––, 250 N.Y.S.3d 260; Grymes Dev. Co., 88 Misc.3d 767, 770, 772–75, 245 N.Y.S.3d 863 [“Amotion predicated on a ‘non-existent case’ is a frivolous filing within the meaning of the Rules of the Chief Administrator forthe imposition of sanctions.”]).Defendant's Motion (M-103087)Turning to the substance of Defendant's motion to change venue, the Court must begin by explaining the venue assignmentprocess in the Court of Claims. The Court of Claims is divided into eight districts, with each district encompassing multiplecounties (see 22 NYCRR 206.4 [a]). The Utica District encompasses, among other counties, Oneida County (see id.). Uponthe filing of a claim, the Chief Clerk of the Court of Claims assigns the claim to the district in which the claim arose (see id.).“[U]nlike actions commenced in State Supreme Court, where a plaintiff initially designates the venue of his lawsuit, in theCourt of Claims the claimant does not have any part in selecting the place of trial” (Ken-Vil Assoc. Ltd. Partnership v. New YorkState Div. of Human Rights, UID No. 2012-030-566, Claim No. 120104 [Ct. Cl., Scuccimarra, J., Sept. 21, 2012]; see Warneyv. State of New York, 16 N.Y.3d 428, 435, 922 N.Y.S.2d 865, 947 N.E.2d 639 [2011] [CPLR only applies in the Court of Claimsto issues not governed by the Court of Claims Act or Uniform Rules for the Court of Claims]).Here, the alleged misconduct by the Defendant occurred primarily within Oneida County at the Taberg Residential Center forGirls in Taberg, New York (see Claim ¶¶ 7-38). Accordingly, the Clerk properly assigned this Claim to the Utica District (see 22NYCRR 206.4 [a]). The attempted designation of Nassau County (or the New York District) as the place of trial has no effecton the assignment or the location of trial (see Warney, 16 N.Y.3d 428 at 434-435, 922 N.Y.S.2d 865, 947 N.E.2d 639; Court
H.F. v. State, 254 N.Y.S.3d 898 (2026)2026 N.Y. Slip Op. 26040WESTLAW©2026Thomson Reuters. No claim to original U.S. Government Works.3of Claims Act § 9 [9]; 22 NYCRR 206.1 [c]). Neither Claimant nor the Court has identified any real precedent suggesting thatCPLR 503 or 509 apply to Court of Claims cases to warrant a different conclusion.If Claimant wanted to request a change of venue of this Claim, Claimant would have needed to make a motion or cross-motionto change venue (see *901 22 NYCRR 206.4 [b]; see also CPLR 510), showing that the current venue is improper. Claimantdid not do so.Accordingly, it is herebyORDERED that Defendant's motion for change of venue (M-103807) is DENIED as moot, and the Claim will remain venuedin the Utica District.Papers Considered:Claim No. 144615, with Summons, dated September 17, 2025.Defendant's Notice of Motion to Change and/or Designate Proper Venue, dated November 17, 2025.Affirmation of Ramona L. Rabeler, Esq. in Support of Defendant's Motion to Change and/or Order Designation of Proper Venue,dated November 17, 2025, with attached Exhibit A.Reply Affirmation of Ramona L. Rabeler, Esq. in Support of Defendant's Motion to Change and/or Order Designation of ProperVenue, dated January 27, 2026.Papers Reviewed but Stricken:1. Affirmation of Timothy Manning, Esq. in Opposition, dated January 21, 2026, with attached Exhibit 1.All Citations254 N.Y.S.3d 898, 2026 N.Y. Slip Op. 26040End of Document© 2026 Thomson Reuters. No claim to original U.S. Government Works.
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