Carpenter v. City of Norwich

CourtAppellate Division of the Supreme Court of the State of New York
DecidedJune 18, 2026
DocketCV-25-0097
StatusPublished

This text of Carpenter v. City of Norwich (Carpenter v. City of Norwich) is published on Counsel Stack Legal Research, covering Appellate Division of the Supreme Court of the State of New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Carpenter v. City of Norwich, (N.Y. Ct. App. 2026).

Opinion

Carpenter v City of Norwich - 2026 NY Slip Op 03855
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Law Reporting
Bureau
Thomas J.K. Smith, State Reporter

Carpenter v City of Norwich

2026 NY Slip Op 03855

June 18, 2026

Appellate Division, Third Department

Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431.

This decision is uncorrected and subject to revision before publication in the Official Reports.

Justin Carpenter, Respondent,

v

City of Norwich et al., Appellants.

Decided and Entered:June 18, 2026

CV-25-0097

Calendar Date: April 23, 2026

Before: Clark, J.P., Aarons, Pritzker, Mcshan And Ryba, JJ.

Johnson & Laws, LLC, Clifton Park (April J. Laws of counsel), for appellants.

Spicer Law Office, Syracuse (Lewis G. Spicer of counsel), for respondent.

[*1]

Pritzker, J.

Appeal from an order of the Supreme Court (Patrick O'Sullivan, J.), entered January 15, 2025 in Chenango County, which partially denied a motion by defendants for summary judgment dismissing the complaint.

Plaintiff, a former police officer with defendant City of Norwich Police Department (hereinafter the Norwich PD), resigned in 2018 in settlement of several charges of misconduct brought against him. Plaintiff thereafter sought law enforcement employment with defendant City of Norwich and with Chenango County, but he was disqualified from eligibility based on his failure to disclose details of his settlement. Although he commenced a subsequent CPLR article 78 proceeding challenging those disqualifications, it was dismissed pursuant to CPLR 3211 (a) (7). In the interim, plaintiff commenced this action asserting causes of action for breach of contract, defamation and intentional infliction of emotional distress. Following joinder of issue, defendants moved for summary judgment dismissing the complaint. Supreme Court granted the motion to the extent of dismissing the complaint against the Norwich PD as well as a claim for punitive damages against the City, and otherwise denied the motion. As relevant here, the court concluded that there were triable issues of fact as to all three causes of action. Defendants appeal from so much of the order as denied their motion for summary judgment.FN1

Defendants contend that they satisfied their prima facie burden of establishing their entitlement to judgment as a matter of law dismissing each of plaintiff's claims and that plaintiff, in response, failed to raise a triable issue of fact. In that regard, we turn our attention first to the defamation cause of action. As relevant here, a claim for defamation requires proof of "a false statement, published without privilege or authorization to a third party, constituting fault as judged by, at a minimum, a negligence standard, and it must either cause special harm or constitute defamation per se" (Rosen v Price Chopper, 239 AD3d 1132, 1133 [3d Dept 2025] [internal quotation marks and citations omitted]; see Carr v Wegmans Food Mkts., Inc., 182 AD3d 667, 669 [3d Dept 2020]). Courts have recognized that certain statements furthering public interests are afforded a qualified privilege from defamation liability that may be overcome only by a showing that "the defendant acted out of personal spite or ill will, with reckless disregard for the statements' truth or falsity, or with a high degree of belief that their statements were probably false" (Radiation Oncology Servs. of Cent. N.Y., P.C. v Our Lady of Lourdes Mem. Hosp., Inc., 221 AD3d 1324, 1333 [3d Dept 2023] [internal quotation marks, brackets and citations omitted]; see Partridge v State of New York, 173 AD3d 86, 96-97 [3d Dept 2019]). These include "good faith communication[s] upon a subject in which [the speaker] has an interest, or a legal, moral or societal interest to speak, and made to a person with a corresponding [*2]interest" (Macumber v South New Berlin Lib., 186 AD3d 1864, 1864 [3d Dept 2020] [internal quotation marks, ellipsis and citations omitted]; see Front, Inc. v Khalil, 24 NY3d 713, 719 [2015]). Accordingly, "[o]n a motion for summary judgment dismissing a defamation [claim], such [claim] is properly dismissed where a qualified privilege obtains and the plaintiff offers an insufficient showing of malice" (Virk v Kaleida Health, 227 AD3d 1422, 1424 [4th Dept 2024] [internal quotation marks, brackets and citations omitted], lv denied 42 NY3d 909 [2024]).

As further relevant here, 9 NYCRR part 6056 establishes a Central State Registry of Police Officers and Peace Officers administered by the Department of Criminal Justice Services (hereinafter DCJS) (see 9 NYCRR 6056.1). At the time of the events giving rise to this suit, employers were required to "immediately notify [DCJS] when an . . . officer ceases to serve," using a designated " 'Registry Update Form' " (9 NYCRR 6056.5 [former (c)]). The regulations additionally provided that such notice must contain "the reason for such" cessation of service, including, as relevant here, "[r]esignation" and "[r]emoval for [c]ause as defined in" 9 NYCRR 6056.2 (former [g]) (9 NYCRR 6056.4 [former (c) (2), (4)]; see also Executive Law § 845 [2] [b]). Removal for cause was defined in relevant part as removal pursuant to a disciplinary hearing under Civil Service Law § 75, a collective bargaining agreement, or other applicable law, or "by an employee's resignation or retirement while a disciplinary process has commenced . . . which may result in removal" (9 NYCRR 6056.2 [former (g) (1)-(2)] [emphasis added]). As this Court explained, whether an officer would be deemed to have resigned "while a disciplinary process has commenced" would "hinge[ ] on whether the disciplinary charges . . . remained pending at the time of [the officer's] resignation" (Matter of Kitto v City of Albany, N.Y. Dept. of Police, 213 AD3d 1165, 1170 [3d Dept 2023] [internal quotation marks and citation omitted]; see generally Matter of Aufiero v New York State Div. of Criminal Justice Servs., 173 AD3d 1320, 1320 [3d Dept 2019], lv denied 34 NY3d 912 [2020]).

In support of defendants' motion for summary judgment, they proffered, among other things, plaintiff's notice of termination, the stipulation of settlement, a police officer registry update form signed by defendant Rodney Marsh — who is chief of police of the Norwich PD — and Marsh's affidavit. The notice of termination indicates that plaintiff was terminated by the Norwich PD in June 2016 on several charges of misconduct stemming from alleged harassment and sexual harassment of subordinate officers. Plaintiff commenced a grievance against the notice of termination and demanded arbitration pursuant to his collective bargaining agreement, but, in August 2017, plaintiff and the City agreed to the stipulation of settlement to avoid the "time, expense, delay and uncertainty" presented by arbitration[*3].

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Carpenter v. City of Norwich, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carpenter-v-city-of-norwich-nyappdiv-2026.