New York Court of Appeals
Howard Desmond, Respondent v. City of New York, Appellant
June 6, 199688 N.Y.2d 455
Summary
The New York Court of Appeals reversed the Appellate Division, holding that the NYPD Chief of Operations Memo No. 3 is not a "requirement" under General Municipal Law § 205‑e and therefore does not give rise to a statutory cause of action for the plaintiff officer’s injuries.