Doscher v Mannatt, Phelps & Phillips, LLP 2017 NY Slip Op 01973 Decided on March 16, 2017 Appellate Division, First Department is a case with Judiciary Law § 487 claims. Supreme Court dismissed and the Appellate Division affirmed for these reasons:
- Collateral estoppel: Plaintiff had two chances in the arbitration and both were denied;
- The arbitration award is a valid final judgment;
- JL § 487 does not apply to anything but court proceedings; not arbitrations or administrative proceedings;
- JL § 487 does not apply to proceedings outside of NYS;
- This misconduct is neither “egregious” enough nor a “chronic and extreme pattern of behavior”.