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
| Court | Appellate Division, First Department |
|---|---|
| Decided | October 8, 2026 |
| Citation | 2026 NY Slip Op 05862 |
| Area of law | Criminal Procedure |
| Week | Week ending October 10, 2026 |
| Official text | Official decision: 2026 NY Slip Op 05862 |
| Publication status | Slip opinions are uncorrected and subject to revision before publication in the Official Reports. |
| Source feed | New York slip opinion page |
| Law Watch record id | 1085 |
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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