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Matter of Camara v. New York City Taxi & Limousine Commn.

Citation: 2021 NY Slip Op 05919Docket: Index No. 161067/20 Appeal No. 14518 Case No. 2021-02259

Court: Appellate Division of the Supreme Court of the State of New York; October 28, 2021; New York; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

Boubacar Camara appealed against the New York City Taxi and Limousine Commission (TLC) regarding the suspension of his for-hire vehicle driver’s license, which was enacted on December 7, 2020. The Supreme Court of New York County, under Judge Eileen A. Rakower, denied Camara's petition challenging the suspension, which was brought pursuant to CPLR article 78. The Appellate Division, First Department, unanimously dismissed the appeal as moot, noting that TLC's reinstatement of Camara's license rendered the challenge to the suspension unnecessary. The court clarified that the mootness doctrine applied despite Camara's claim for lost earnings, as such damages were not incidental to the primary relief sought. The decision and order were entered on October 28, 2021.

Legal Issues Addressed

Damages Not Incidental to Primary Relief

Application: The court determined that claims for lost earnings did not prevent the application of the mootness doctrine since they were not incidental to the primary relief sought.

Reasoning: The court clarified that the mootness doctrine applied despite Camara's claim for lost earnings, as such damages were not incidental to the primary relief sought.

Mootness Doctrine in Appeals

Application: The court dismissed the appeal on the grounds of mootness because the primary issue was already resolved by the reinstatement of the appellant's license.

Reasoning: The Appellate Division, First Department, unanimously dismissed the appeal as moot, noting that TLC's reinstatement of Camara's license rendered the challenge to the suspension unnecessary.