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Appellate Division, First Department · October 8, 2026 · 2026 NY Slip Op 05862

People v Sneed

Read the official decision: 2026 NY Slip Op 05862

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Holding The court affirmed the conviction, determining that the store’s loss prevention employees were not state actors because their conduct did not become so pervaded by governmental involvement that it lost its private character. The court found that merely using NYPD forms, calling 911, and waiting for police custody was insufficient to transform the private security staff into state actors.

The court’s words

This conduct fell short of transforming the private security staff into state actors because their conduct did not become so pervaded by governmental involvement that it los[t] its [private] character

2026 NY Slip Op 05862, at the official text
CourtAppellate Division, First Department
DecidedOctober 8, 2026
Citation2026 NY Slip Op 05862
Area of lawCriminal Procedure
WeekWeek ending October 10, 2026
Official textOfficial decision: 2026 NY Slip Op 05862
Publication statusSlip opinions are uncorrected and subject to revision before publication in the Official Reports.
Source feedNew York slip opinion page
Law Watch record id1085

Recommended citation

ESQ HQ, New York Law Watch, People v Sneed, 2026 NY Slip Op 05862 (Appellate Division, First Department, October 8, 2026), https://esqhq.com/decisions/2026-ny-slip-op-05862/

How this record was made

Holding drafted by Law Watch’s in-house model, graded by three reviewers; every quotation verified word for word against the official text.

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Published October 8, 2026. Updated October 8, 2026.