In the Nevada state court system , the Nevada District Courts are the trial courts of general jurisdiction , where criminal, civil, family, and juvenile matters are generally resolved through arbitration, mediation, and bench or jury trials.
131-682: There are business court programs in two Nevada District Courts, the Eighth Judicial District in Law Vegas , and the Second Judicial District in Reno . Brent T. Adams was the first business court judge in Reno. The District Courts also hear appeals from the limited jurisdiction state courts, which are composed of 17 Municipal Courts (which handle involving traffic ticket and misdemeanor violations of ordinances occurring within
262-644: A chateau on Castle Island , within present-day Albany; it was abandoned the following year due to flooding. In 1614, the Dutch, under the command of Hendrick Corstiaensen, rebuilt the French chateau, which they called Fort Nassau . Fort Nassau was the first Dutch settlement in North America, and was located along the Hudson River, also within present-day Albany. The small fort served as a trading post and warehouse. Located on
393-608: A humid subtropical climate . Weather in New York is heavily influenced by two continental air masses: a warm, humid one from the southwest and a cold, dry one from the northwest. Downstate New York (comprising New York City, Long Island, and lower portions of the Hudson Valley) have rather hot summers with some periods of high humidity and cold, damp winters which are relatively mild compared to temperatures in Upstate New York, due to
524-707: A state in the Northeastern United States . One of the Mid-Atlantic states, it borders the Atlantic Ocean , New England , Canada, and the Great Lakes . With almost 19.6 million residents, it is the fourth-most populous state in the United States , and the 27th-largest state by area , with a total area of 54,556 square miles (141,300 km ). New York has a varied geography . The southeastern part of
655-783: A Business Litigation Resource Committee. Arizona's Supreme Court created the Commercial Court Review Committee. Iowa's State Court Administration has made annual reviews of the Iowa Business Specialty Court . Tennessee's Supreme Court created a Business Court Docket Advisory Commission. The North Carolina Administrative Office of the Courts submits annual reports on the North Carolina Business Court. West Virginia's Business Court Division makes annual reports. Wisconsin's Supreme Court created
786-578: A Task Force on Courts. Other examples of states creating task forces to study and make recommendations concerning the implementation of business courts include, among others, Indiana, Michigan, West Virginia, Arizona, Georgia, Iowa, New Jersey, Ohio, Delaware, Mississippi (no court created), Texas, and Oklahoma (May 2024). Other groups have studied and reported on operations and practices in functioning business and commercial courts, to provide information and/or recommendations. Massachusetts, Superior Court Chief Justice Suzanne V. DelVecchio created
917-657: A business court, but did not pursue it, and the Denver District Court later experimented for three years with a business court, known as the Civil Access Pilot Project. Orlando's business court was restored in October 2019, after an earlier funding shortage. In 2015, New Jersey's Supreme Court created a statewide Complex Business Litigation Program after having only a few counties with business courts before that. In 2009, Milwaukee 's Circuit Court ended
1048-519: A career most natives had turned to in hopes of trading with whites first. This completely changed the ethnography of the region, and most large game was hunted out before whites ever fully explored the land. Still, afterward, the Iroquois Confederacy offered shelter to refugees of the Mascouten , Erie, Chonnonton , Tutelo , Saponi , and Tuscarora nations. The Tuscarora became the sixth nation of
1179-945: A current officer of the ACBCJ (as of May 2024), has spoken at its judicial education programs, and participated in its first meeting in 2005. Business and Commercial courts exist internationally as well. Commercial courts outside the United States may have broader or narrower jurisdiction than state trial level business and commercial courts within the United States, for example patent or admiralty jurisdiction; and jurisdiction may vary between countries. Examples exist in England and Wales , Toronto , Montreal , Quebec , and Alberta , Canada , Ireland , Scotland , Denmark , Hong Kong , Belgium , Bermuda , Queensland and Victoria ( Commercial Court ), Australia , New Zealand (Commercial Panel), Northern Ireland , Spain , in France (where
1310-596: A defined list of case types (ii) combined with a specified minimum amount of damages in controversy , irrespective of complexity. In New York , for example, the trial level Supreme Court Commercial Division follows the case type and jurisdictional amount in controversy model, giving jurisdiction over 12 listed business and commercial case categories while setting out monetary thresholds ranging from $ 50,000 in some counties to $ 500,000 in Manhattan. The Massachusetts Superior Court 's Business Litigation Session (BLS) includes
1441-618: A forum for adjudicating disputes between parties from different nations, and not as a means to reference commercial courts in a country other than the United States. New English language commercial courts have been created in Paris , Frankfurt , the Netherlands , Stuttgart and Mannheim , Germany , Singapore , Abu Dhabi , Qatar , and Dubai (the DIFC Courts ), Kazakhstan (Astana International Financial Center) , and Bahrain . This reflects
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#17328444452931572-415: A judge to more subjectively determine if they are complex enough to include on the docket. North Carolina's Business Court has a similar mixed model that makes jurisdiction mandatory if the listed commercial case type is over $ 5,000,000, but discretionary if under, as well as a seldom used rule allowing judicial discretion. The modern creation of specialized Business Courts in the United States began in
1703-776: A jurisdictional list of case types, but instead of focusing on monetary thresholds as a gatekeeping mechanism, cases are included only where "the BLS in the sound discretion of the BLS Administrative Justice, based principally on the complexity of the case and the need for substantial case management," selects a case for inclusion. There are mixed models as well, with some mandatory case type categories specifically listed, and other discretionary types requiring an element of complexity. The Maryland Circuit Court 's Business and Technology Case Management Program includes certain "presumptive" mandatory case types, while others categories require
1834-533: A little used business court program, but Wisconsin's Supreme Court implemented a business court pilot program in 2017 which has expanded to a number of circuit courts and judicial districts, which project has now been ended as of October 2024. In May 2024, Oklahoma enacted a law creating a task force to study business courts. The Hamilton County, Ohio Court of Common Pleas in Cincinnati discontinued its Commercial Docket in 2017, but revived it in 2024. There
1965-682: A major threat to the Abenaki and Mohicans, while the Susquehannock briefly conquered the Lenape in the 1600s. The most devastating event of the century, however, was the Beaver Wars . From approximately 1640–1680, the Iroquois peoples waged campaigns which extended from modern-day Michigan to Virginia against Algonquian and Siouan tribes, as well as each other. The aim was to control more land for animal trapping ,
2096-623: A mix of UK parties and international parties. There is a view that the more recently created commercial courts designed to hear disputes between parties of different nations will compete with the London based commercial courts as the preferred litigation forum for international commercial disputes. In 2017, New York's Commercial Division added a "Large Complex Case List," modeled on the Business and Property Courts' Financial List for high stakes commercial litigation, as part of an overall effort to compete with
2227-556: A private consulting firm's study to create a business court in Atlanta (Fulton County Superior Court); and a good government organization (The Committee of Seventy ) study of Philadelphia's Commerce Case Management Program. The NCSC, working with the Tennessee Administrative Office of the Courts, also has developed a curriculum and faculty guide for creating business courts. The American College of Business Court Judges
2358-1264: A rich history with noteworthy milestones." Some states have established specialized business and commercial courts that include technology disputes as part of their express jurisdiction. Through legislative effort and court rule, in 2003, Maryland established a Business and Technology Case Management Program. In May 2003, Delaware expanded the Court of Chancery's jurisdiction to include technology disputes. West Virginia's Business Court Division Rules includes technology issues. The Tennessee's Business Court Docket encompasses technology and biotechnology licensing. North Carolina's Business Court jurisdiction includes computer software, information technology and systems, data and data system security, biotechnology and bioscience technology. Michigan's business court jurisdiction includes disputes "involving information technology, software, or website development, maintenance, or hosting...." Wyoming Chancery Court Rules provide jurisdiction over disputes concerning registered digital assets. New York's Commercial Division Rule were amended in 2024 to expressly include "technology transactions and/or commercial disputes involving or arising out of technology". This amendment
2489-583: A small group known as the Ouabano migrated southwest into West Virginia at an earlier time. They may have merged with the Shawnee . The Mohawk and Susquehannock were the most militaristic . Trying to corner trade with the Europeans, they targeted other tribes. The Mohawk were also known for refusing white settlement on their land and discriminating against any of their people who converted to Christianity . They posed
2620-641: A temperature of −13 °F (−25 °C) or lower can be expected in the northern highlands (Northern Plateau) and 5 °F (−15 °C) or colder in the southwestern and east-central highlands of the Southern Tier. New York had a record-high temperature of 108 °F (42.2 °C) on July 22, 1926, in the Albany area. Its record-lowest temperature during the winter was −52 °F (−46.7 °C) in 1979. Governors Island, Manhattan , in New York Harbor ,
2751-588: A total area of 54,555 square miles (141,297 km ) and ranks as the 27th-largest state by size . The highest elevation in New York is Mount Marcy in the Adirondack High Peaks in Northern New York , at 5,344 feet (1,629 meters) above sea level ; while the state's lowest point is at sea level, on the Atlantic Ocean in Downstate New York . In contrast with New York City's urban landscape,
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#17328444452932882-554: A trial level Business Court and an appellate business court, the Fifteenth Court of Appeals. These courts have been open for cases since September 1, 2024. In August 2024, the Texas Supreme Court rejected a constitutional challenge to the appellate business court's creation. While Wisconsin still has the remnant of a business court as of October 2024, by a 4-3 vote its Supreme Court issued an order on October 7, 2024, ending
3013-592: A water border with Rhode Island , while Connecticut has land and sea borders. Except for areas near the New York Harbor and the Upper Delaware River , New York has a mostly land border with two Mid-Atlantic states , New Jersey and Pennsylvania . New York is the only state that borders both the Great Lakes and the Atlantic Ocean . The Hudson River begins near Lake Tear of the Clouds and flows south through
3144-401: Is a distinct type of specialized civil litigation docket designed to handle complex litigation, often referred to as complex civil litigation programs or complex civil litigation courts. At least California , Connecticut , Oregon , and Minnesota courts have created specialized dockets for complex civil litigation within their civil trial courts. These programs define jurisdiction through
3275-524: Is a past president of the American College of Business Court Judges (ACBCJ), and a number of California's complex litigation judges (including judge Elihu Berle ), and Minnesota complex litigation judge Jerome B. Abrams , have served as Business Court Representatives to the American Bar Association 's Section of Business Law. Abrams is a 2023-2024 vice president of the ACBCJ. Berle is also
3406-460: Is among the largest university systems in the nation. New York City is home to the headquarters of the United Nations , and it is sometimes described as the world's most important city, the cultural , financial , and media epicenter, and the capital of the world. The Native American tribes in what is now New York were predominantly Iroquois and Algonquian . Long Island
3537-586: Is anchored by the city of Syracuse ; between the central and western parts of the state, New York is dominated by the Finger Lakes , a popular tourist destination. To the south, along the state border with Pennsylvania , the Southern Tier sits atop the Allegheny Plateau , representing some of the northernmost reaches of Appalachia . New York was one of the original Thirteen Colonies that went on to form
3668-516: Is covered by ice. The summer climate is cool in the Adirondacks, Catskills, and at higher elevations of the Southern Tier. Buffalo and its metropolitan area are described as climate change havens for their weather pattern in Western New York. Summer daytime temperatures range from the high 70s to low 80s °F (25 to 28 °C), over most of the state. In the majority of winter seasons,
3799-833: Is intended to make clear that New York is as experienced in handling technology as any other state's courts. There are also examples of international courts expressly addressing technology disputes as part of their jurisdiction. Singapore's International Commercial Court includes a Technology, Infrastructure, and Construction List. The Commercial Court within Ireland's High Court has an the Intellectual Property and Technology division. The Victoria, Australia Commercial Court expressly includes jurisdiction over "Proceedings relating to technology, engineering and/or construction...." The DIFC Courts Technology and Construction Division has jurisdiction over, among other things, "claims relating to
3930-528: Is planned to host a US$ 1 billion research and education center poised to make New York the global leader in addressing the climate crisis . Due to New York's relatively large land area and unique geography compared to other eastern states, there are several distinct ecoregions present in the state, many of them reduced heavily due to urbanization and other human activities: Southern Great Lakes forests in Western New York , New England–Acadian forests on
4061-637: Is shared between New York and Ontario as it flows on the Niagara River from Lake Erie to Lake Ontario. The Delaware River Basin Compact, signed in 1961 by New York, New Jersey, Pennsylvania , Delaware , and the federal government, regulates the utilization of water of the Delaware system. Under the Köppen climate classification , most of New York has a humid continental climate , though New York City and Long Island have
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4192-514: Is true for New York City: four of its five boroughs are situated on three islands at the mouth of the Hudson River : Manhattan Island ; Staten Island ; and Long Island , which contains Brooklyn and Queens at its western end. The state's borders include a water boundary in (clockwise from the west) two Great Lakes ( Lake Erie and Lake Ontario , which are connected by the Niagara River );
4323-491: Is well recognized, both in seeing business courts as a competitor forum with arbitration, and in using ADR as a complementary adjunct to the litigation process. Thus, for example, New York Commercial Division Rule 3 allows for court appointed mediators and neutral evaluators, Philadelphia's Commerce Case Management Program created an alternative dispute resolution program using Judges Pro Tempore in mandated settlement conferences, and discretionary referrals to private mediation,
4454-457: Is when the first modern business court programs began in the United States. The list does not include Chancellors and Vice-Chancellors from the Delaware Court of Chancery, which has been a pre-eminent business court for over a century, and whose judges have held an important place as business court judges over that time. New York (state) New York , also called New York State , is
4585-564: The Adirondack Mountains and the Catskill Mountains (part of the wider Appalachian Mountains ). The east–west Mohawk River Valley bisects the more mountainous regions of Upstate and flows into the north–south Hudson River valley near the state capital of Albany . Western New York , home to the cities of Buffalo and Rochester , is part of the Great Lakes region and borders Lake Ontario and Lake Erie . Central New York
4716-519: The American Civil War , in terms of finances, volunteer soldiers, and supplies. The state provided more than 370,000 soldiers to the Union armies. Over 53,000 New Yorkers died in service, roughly one of every seven who served. However, Irish draft riots in 1862 were a significant embarrassment. Since the early 19th century, New York City has been the largest port of entry for legal immigration into
4847-637: The Capital Region entered Phase 1 of reopening. On May 26, the Hudson Valley began Phase 1, and New York City partially reopened on June 8. During July 2020, a federal judge ruled Governor Andrew Cuomo and Mayor Bill de Blasio exceeded authority by limiting religious gatherings to 25% when others operated at 50% capacity. On Thanksgiving Eve, the U.S. Supreme Court blocked additional religious restrictions imposed by Cuomo for areas with high infection rates. The state of New York covers
4978-597: The Continental Army at the Battle of Saratoga in 1777, a success that influenced France to ally with the revolutionaries; the state constitution was enacted in 1777. New York became the 11th state to ratify the United States Constitution , on July 26, 1788. In an attempt to retain their sovereignty and remain an independent nation positioned between the new United States and British North America , four of
5109-459: The Declaration of Independence on July 9, 1776. The New York State Constitution was framed by a convention which assembled at White Plains on July 10, 1776, and after repeated adjournments and changes of location, finished its work at Kingston on Sunday evening, April 20, 1777, when the new constitution drafted by John Jay was adopted with but one dissenting vote. It was not submitted to
5240-511: The Georgia State-wide Business Court , Delaware 's Superior Court and Court of Chancery , Nashville , Tennessee , Indiana , Phoenix , Arizona , Kentucky , South Carolina , West Virginia , and Wyoming , as well as Utah and Texas . In 2023, Utah adopted legislation creating a statewide Business and Chancery Court , which became operational on October 1, 2024. In 2023, Texas' governor signed legislation creating
5371-681: The Great Lakes , with the port of New York City. Improving transportation, it enabled additional population migration to territories west of New York. After 1850, railroads largely replaced the canal. The connectivity offered by the canal, and subsequently the railroads, led to an economic boom across the entire state through the 1950s. Major corporations that got their start in New York during this time include American Express , AT&T , Bristol Myers Squibb , Carrier , Chase , General Electric , Goldman Sachs , IBM , Kodak , Macy's , NBC , Pfizer , Random House , RCA , Tiffany & Co. , Wells Fargo , Western Union , and Xerox . New York City
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5502-741: The Iroquois Nations fought on the side of the British; only the Oneida and their dependents, the Tuscarora, allied themselves with the Americans. In retaliation for attacks on the frontier led by Joseph Brant and Loyalist Mohawk forces , the Sullivan Expedition of 1779 destroyed nearly 50 Iroquois villages, adjacent croplands and winter stores, forcing many refugees to British-held Niagara. As allies of
5633-719: The Lake Champlain Valley . The Great Appalachian Valley dominates eastern New York and contains Lake Champlain Valley as its northern half and the Hudson Valley as its southern half within the state. The Tug Hill region arises as a cuesta east of Lake Ontario . The state of New York contains a part of the Marcellus shale , which extends into Ohio and Pennsylvania. Upstate and Downstate are often used informally to distinguish New York City or its greater metropolitan area from
5764-528: The New England border, Northeastern coastal forests in the lower Hudson Valley and western Long Island , Atlantic coastal pine barrens in southern Long Island, Northeastern interior dry–mesic oak forest in the eastern Southern Tier and upper Hudson Valley, Appalachian–Blue Ridge forests in the Hudson Valley), Central Appalachian dry oak–pine forest around the Hudson Valley, Eastern Great Lakes and Hudson Lowlands , Eastern forest–boreal transition in
5895-639: The New York State Legislature created the Board of Commissioners of Immigration to regulate immigration. The first permanent immigration depot in New York was established in 1855 at Castle Garden , a converted War of 1812 era fort located within what is now Battery Park , at the tip of Lower Manhattan. The first immigrants to arrive at the new depot were aboard three ships that had just been released from quarantine . Castle Garden served as New York's immigrant depot until it closed on April 18, 1890, when
6026-423: The Philadelphia Convention , which drafted the United States Constitution, in which he also took part. The new government was to be a strong federal national government to replace the relatively weaker confederation of individual states. Following heated debate, which included the publication of The Federalist Papers as a series of installments in New York City newspapers, New York was the 11th state to ratify
6157-481: The Province of New York . During the American Revolutionary War , a group of colonists eventually succeeded in establishing independence, and the state ratified the then new United States Constitution in 1788. From the early 19th century, New York's development of its interior, beginning with the construction of the Erie Canal , gave it incomparable advantages over other regions of the United States. The state built its political, cultural, and economic ascendancy over
6288-481: The Rolls Building , encompass 13 different courts or lists, for example, the Commercial Court, the Business List, and the Intellectual Property Enterprise Court . One object of creating this consolidated forum for the business and commercial courts of England and Wales was to maintain the international preeminence of their courts for dispute resolution. In 2023, 40% of London 's Commercial Court cases involved opposing parties from different nations, and 64% involved
6419-418: The Susquehannock and the Erie . Many of the Wampanoag and Mohican peoples were caught up in King Philip's War , a joint effort of many New England tribes to push Europeans off their land. After the death of their leader, Chief Philip Metacomet , most of those peoples fled inland, splitting into the Abenaki and the Schaghticoke . Many of the Mohicans remained in the region until the 1800s, however,
6550-481: The Uniform commercial code , complex contracts, intellectual property, and business torts), Minnesota (ownership or control of businesses cases), and Lane County, Oregon's Commercial Court that expressly includes within its jurisdiction both commercial and non-commercial complex cases. The San Francisco Superior court complex civil litigation program helps deal with business litigation in that court. Former Orange County Complex Litigation Program judge Gail A. Andler
6681-476: The United States Constitution , on July 26, 1788. New York City remained the national capital under the new constitution until 1790 when it was moved to Philadelphia until 1800, when it was relocated to its current location in Washington, D.C. and was the site of the inauguration of President George Washington, In the first session of the Supreme Court of the United States , the United States Bill of Rights were drafted. Transportation in Western New York
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#17328444452936812-436: The United States Court of Appeals for the Seventh Circuit , and the Delaware Supreme Court . Retired Seventh Circuit Judge Richard Posner wrote that in the nineteenth century and well into the twentieth century, "t]he New York Court of Appeals was the nation's premier commercial court." The United States Court of Appeals for the Second Circuit has been similarly described as "the country's leading commercial court during
6943-471: The World Trade Center site . On October 29 and 30, 2012, Hurricane Sandy caused extensive destruction of the state's shorelines, ravaging portions of New York City, Long Island , and southern Westchester with record-high storm surge , with severe flooding and high winds causing power outages for hundreds of thousands of New Yorkers, and leading to gasoline shortages and disruption of mass transit systems. The storm and its profound effects have prompted
7074-418: The city limits of incorporated municipalities ) and 45 Justice Courts (which handle misdemeanor crime and traffic matters, small claims , evictions , and other civil matters in which the amount in controversy is less than $ 10,000, as well as felony and gross misdemeanor arraignments and preliminary hearings to determine if sufficient evidence exists for a trial in the District Court). Appeals from
7205-517: The ring-necked pheasant , northern bobwhite , ruffed grouse , spruce grouse , Canada jay , wild turkey , blue jay , eastern bluebird (the state bird ), American robin , and black-capped chickadee . Birds of prey that are present in the state are great horned owls , bald eagles , red-tailed hawks , American kestrels , and northern harriers . Waterfowl like mallards , wood ducks , canvasbacks , American black ducks , trumpeter swans , Canada geese , and blue-winged teals can be found in
7336-539: The white-footed mouse , North American least shrew , little brown bat , muskrat , eastern gray squirrel , eastern cottontail , American ermine , groundhog , striped skunk , fisher , North American river otter , raccoon , bobcat , eastern coyote , red fox , gray fox white-tailed deer , moose , and American black bear ; extirpated mammals include Canada lynx , American bison , wolverine , Allegheny woodrat , caribou , eastern elk , eastern cougar , and eastern wolf . Some species of birds in New York are
7467-521: The 1940s and 1950s...." India's Commercial Courts law includes provisions for specialized commercial appellate divisions. There is a Netherland's Commercial Court of Appeals, and Enterprise Chamber of the Amsterdam Court of Appeals. Singapore's International Commercial Court is designated to hear appeals from Bahrain's International Commercial Court. The significant relationship between business courts and alternative dispute resolution (ADR), such as mediation , neutral evaluation, and arbitration ,
7598-548: The Adirondacks, Eastern Great Lakes lowland forests around the Adirondacks, and Allegheny Highlands forests , most of which are in the western Southern Tier. Some species that can be found in this state are American ginseng , starry stonewort , waterthyme , water chestnut, eastern poison ivy , poison sumac , giant hogweed , cow parsnip and common nettle . There are more than 70 mammal species, more than 20 bird species, some species of amphibians, and several reptile species. Species of mammals that are found in New York are
7729-438: The British, the Iroquois were forced out of New York, although they had not been part of treaty negotiations. They resettled in Canada after the war and were given land grants by the Crown. In the treaty settlement, the British ceded most Indian lands to the new United States. Because New York made a treaty with the Iroquois without getting Congressional approval, some of the land purchases have been subject to land claim suits since
7860-519: The Business Courts Advisory Committee. In 2023, Utah's Supreme Court created an Advisory Committee on the Rules of Business and Chancery Procedure. Some councils and committees take an active role in business courts' ongoing operations. In 2013, New York Court of Appeals Chief Judge Jonathan Lippman established the New York Commercial Division Advisory Council (CDAC) to implement an earlier task force's recommendations. The CDAC "is composed of distinguished commercial practitioners and Judges from around
7991-764: The Business Law Section's Business and Corporate Litigation Committee; the development of a Business Court Representatives Program; and a clerkship program placing law students with business court judges for summer clerkships. The Business Law Section's Judges Initiative Committee was inspired by North Carolina Business Court Judge Ben F. Tennille (as was the Business Court Representatives Program), who served as its first judicial co-chair. South Carolina Business Court Judge Clifton Newman , Michigan Business Court Judge Christopher P. Yates , and New York Commercial Division Judge Timothy S. Driscoll have also served as Judges Initiative Committee co-chairs. Private entities have also carried out implementation or operational studies at
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#17328444452938122-439: The Commercial Docket statewide. The Kentucky Bar Association 's Business Law Section put on early programming about Kentucky's newly established business court. The American Bar Association has a long history in supporting the development of business courts, including, among other things, the creation of an Ad Hoc Committee on Business Courts in the 1990s, which evolved into the permanent Business Courts Subcommittee within
8253-474: The Complex Business Litigation Division and International Commercial Arbitration Court judges. Following is a non-exhaustive list of business court judges serving over a period of years in U.S. business and commercial courts, in and after 1993, and/or identifying many judges who were pioneers on their bench and/or have had an impact beyond their bench, such as participation in the American College of Business Court Judges (ACBCJ) or American Bar Association. 1993
8384-685: The DIFC Courts' "Court Users Committee" and Rules Committee, Scotland's Consultive Committee on Commercial Actions, the Singapore International Commercial Courts Committee, Rwanda's Business Law Reform Cell, and Kenya's Business Court Users Committee. Bar associations are also involved. The Philadelphia Bar Association's Business Litigation Committee plays a role in selecting lawyers as Judges Pro Tempore to serve as court appointed neutrals in Philadelphia Commerce Court cases. The Chicago Bar Association created its Commercial Litigation Committee "to promote discourse between judges and lawyers who handle business-related disputes" with an initial focus on
8515-416: The Economy, New York Chief Judge Judith S. Kaye created a Commercial Courts Task Force, a Nevada Legislative Commission formed a Subcommittee to Encourage Corporations and Other Business Entities to Organize and Conduct Business in this State, Maryland's General Assembly created a Business and Technology Court Task Force, and the South Carolina Bar , with South Carolina Supreme Court approval, created
8646-475: The Fifteenth Court of Appeals. It is the first operational specialized appellate level business court in the United States. In 2020, Pennsylvania passed a law encouraging the Superior Court of Pennsylvania to create a specialized appellate Commerce Court, but that Pennsylvania intermediate appellate court has not done so. Other appellate courts have been described as commercial or business courts, not by design, but in reference to their actual case work, such as
8777-466: The Hudson River flood plain, the rudimentary fort was washed away by flooding in 1617, and abandoned for good after Fort Orange (New Netherland) was built nearby in 1623. Henry Hudson's 1609 voyage marked the beginning of European involvement in the area. Sailing for the Dutch East India Company and looking for a passage to Asia, he entered the Upper New York Bay on September 11 of that year. Word of his findings encouraged Dutch merchants to explore
8908-482: The Iroquois Confederacy include the Seneca, Cayuga, Onondaga, Oneida, Tuscarora and Mohawk. The Iroquois fought for both sides during the Revolutionary War ; afterwards many pro-British Iroquois migrated to Canada. Today, the Iroquois still live in several enclaves across New York and Ontario. Meanwhile, the Lenape formed a close relationship with William Penn . However, upon Penn's death, his sons managed to take over much of their lands and banish them to Ohio. When
9039-414: The Iroquois. In the 1700s, Iroquoian peoples would take in the remaining Susquehannock of Pennsylvania after they were decimated in the French and Indian War . Most of these other groups assimilated and eventually ceased to exist as separate tribes. Then, after the American Revolution , a large group of Seneca split off and returned to Ohio, becoming known as the Mingo Seneca. The current Six Nations of
9170-506: The King of France's sister . Verrazzano described it as "a vast coastline with a deep delta in which every kind of ship could pass" and he adds: "that it extends inland for a league and opens up to form a beautiful lake. This vast sheet of water swarmed with native boats." He landed on the tip of Manhattan and possibly on the furthest point of Long Island. Verrazzano's stay was interrupted by a storm which pushed him north towards Martha's Vineyard . In 1540, French traders from New France built
9301-429: The Law Division's Commercial Calendars. The Boston Bar Association 's Business and Commercial Litigation Section holds an annual event, "Business Litigation Session Year in Review", where lawyers hear directly from Business Litigation Session judges. The Florida Bar 's Business Law Section has a Business Courts Task Force. The Ohio State Bar Association 's Corporation Law Committee urged a detailed resolution to expand
9432-622: The Lenape. In 1524, Giovanni da Verrazzano , an Italian explorer in the service of the French crown , explored the Atlantic coast of North America between the Carolinas and Newfoundland , including New York Harbor and Narragansett Bay . On April 17, 1524, Verrazzano entered New York Bay , by way of the strait now called the Narrows into the northern bay which he named Santa Margherita, in honor of
9563-420: The London based commercial courts as a preferred forum for international litigation. The jurisdictional scope of commercial courts outside the United States may have some differences with American state level specialized business and commercial courts. For example, the Business and Property Courts of England and Wales include specialized courts or lists for admiralty , insolvency , and patents , which in
9694-581: The Metro Atlanta Business Case Division are empowered to hear court-based disputes concerning international arbitration proceedings. A substantial part of the Commercial Court of England and Wales' docket involves arbitration appeals. The Miami-Dade County, Florida Circuit Court has an International Commercial Arbitration Court. Miami circuit judges Jennifer D. Bailey and Lisa S. Walsh have served as both business court judges in
9825-986: The Nevada District Courts are taken directly by the Supreme Court of Nevada . Following a deflective model of appeals, the Supreme Court of Nevada has discretion to assign cases to the three-member Court of Appeals. It is expected that most cases will be finally resolved by the Court of Appeals, from which further appeal will be heard by the Supreme Court of Nevada only in extraordinary cases. There are 82 judges sitting in 11 district courts, each covering one or more of Nevada's 16 counties and one independent city : Business courts Business courts , sometimes referred to as commercial courts , are specialized courts for legal cases involving commercial law , internal business disputes, and other matters affecting businesses. In
9956-687: The North Carolina Business Court Rules address mandatory mediation, and Florida's Ninth Judicial Circuit Business Court Procedures, Section 8, requires mandatory ADR, and addresses non-binding arbitration as well as mediation. The Michigan Supreme Court business court case management standards emphasize early mediation. International examples include, among others, the Business and Property Courts of England and Wales Commercial Court Guide, Section G, addressing "Negotiated Dispute Resolution", Ireland's Commercial List, section 6(a)(b)(xiii), giving its judges power to adjourn proceedings so
10087-634: The SIFoCC has held five full meetings, with dozens of judges from around the world, most recently in April 2024 in Doha , Qatar. In its 2023 policy resolution, the Association of Corporate Counsel recognizes and endorses the creation and support of business courts internationally, as well as in the United States. In the United States and internationally, "[t]he notion of specialized courts to decide technology disputes has
10218-573: The Twin Towers of the original World Trade Center in Lower Manhattan , and the towers collapsed . 7 World Trade Center also collapsed due to damage from fires. The other buildings of the World Trade Center complex were damaged beyond repair and demolished soon thereafter. The collapse of the Twin Towers caused extensive damage and resulted in the deaths of 2,753 victims, including 147 aboard
10349-654: The U.S. drafted the Indian Removal Act , the Lenape were further moved to Missouri, whereas their cousins, the Mohicans, were sent to Wisconsin. Also, in 1778, the United States relocated the Nanticoke from the Delmarva Peninsula to the former Iroquois lands south of Lake Ontario, though they did not stay long. Mostly, they chose to migrate into Canada and merge with the Iroquois, although some moved west and merged with
10480-909: The US, they are trial courts that primarily or exclusively adjudicate internal business disputes and/or commercial litigation between businesses, heard before specialist judges assigned to these courts. Commercial courts outside the United States may have broader or narrower jurisdiction than state trial level business and commercial courts within the United States, for example patent or admiralty jurisdiction; and jurisdiction may vary between countries. Business courts may be further specialized, as in those that decide technology disputes and those that weigh appeals . Alternative dispute resolution and arbitration have connections to business courts. Business courts and commercial courts are specialized courts for cases involving commercial law , internal business disputes, and other matters affecting businesses. Business courts in
10611-467: The United States . In the United States, the federal government did not assume direct jurisdiction for immigration until 1890. Prior to this time, the matter was delegated to the individual states, then via contract between the states and the federal government. Most immigrants to New York would disembark at the bustling docks along the Hudson and East Rivers , in the eventual Lower Manhattan . On May 4, 1847,
10742-444: The United States are trial courts that primarily or exclusively adjudicate internal business disputes and/or commercial litigation between businesses, heard before specialist judges assigned to these courts. They have been established in approximately twenty-seven states. In some cases, a state legislature may choose to create a business court by statute. In other cases, business courts have been established by judicial rule or order, at
10873-456: The United States can trace their ancestry to these immigrants. Ellis Island was the subject of a contentious and long-running border and jurisdictional dispute between the State of New York and the State of New Jersey, as both claimed it. The issue was officially settled in 1998 by the U.S. Supreme Court which ruled that the original 3.3-acre (1.3 ha) island was New York state territory and that
11004-515: The United States provides considerable examples of task forces, advisory bodies, bar associations and other entities involved in their creation, development and refinement, and in providing education on their operations. A number of business courts were created after studies carried out by task forces preceding a business court's creation. For example, North Carolina's Governor established the North Carolina Commission on Business Laws and
11135-560: The United States would typically be subject to jurisdiction in federal tribunals, such as the United States Bankruptcy Courts or the United States District Courts , and not in specialized state trial level business courts. The scope of any commercial court's jurisdiction may vary between countries. The Standing International Forum of Commercial Courts (SIFoCC) was created in 2016. From 2017 through 2024,
11266-594: The United States. The area of present-day New York had been inhabited by tribes of the Algonquians and the Iroquois Confederacy Native Americans for several thousand years by the time the earliest Europeans arrived. Stemming from Henry Hudson 's expedition in 1609, the Dutch established the multiethnic colony of New Netherland in 1621. England seized the colony from the Dutch in 1664, renaming it
11397-596: The alternative dispute resolution of business and commercial disputes. This includes the use of mediation, Masters in Chancery to adjudicate matters, and agreements to make decisions non-appealable. Other states have a mixed history. In New York, Chicago, Philadelphia, Massachusetts, North Carolina, South Carolina, and New Jersey, among other locations with business courts, the original programs have expanded by adding judges and/or by expanding into additional cities and counties. Around 2000, Colorado's Supreme Court studied
11528-470: The assignment of new cases to the commercial court pilot project, first established by that court in April 2017. Delaware's Court of Chancery, the pre-eminent court addressing intra-business disputes, has functioned as a business court of limited jurisdiction for over a century. However, its traditional equity jurisdiction has evolved and expanded since 2003 to include technology disputes, some purely monetary commercial disputes, and to expand its role in
11659-599: The balance of the 27.5 acres (11 ha) added after 1834 by landfill was in New Jersey. In May 1964, Ellis Island was added to the National Park Service by President Lyndon B. Johnson and is still owned by the federal government as part of the Statue of Liberty National Monument . In 1990, Ellis Island was opened to the public as a museum of immigration. On September 11, 2001, two of four hijacked planes were flown into
11790-821: The behest of courts. Some examples are: the Institute for the Advancement of the American Legal System studies and reports for Colorado's pilot business courts (Civil Access Pilot Project); the National Center for State Courts (NCSC) Commercial Court Evaluation for the Superior Court of Arizona in Maricopa County and its study of civil programs in Philadelphia's Court of Common Pleas (including its Commerce Court);
11921-502: The canal carrying passengers and freight. Farm products came in from the Midwest , and finished manufactured goods moved west. It was an engineering marvel which opened up vast areas of New York to commerce and settlement. It enabled Great Lakes port cities such as Buffalo and Rochester to grow and prosper. It also connected the burgeoning agricultural production of the Midwest and shipping on
12052-621: The city on October 19 of that year, composed of representatives from across the Thirteen Colonies who set the stage for the Continental Congress to follow. The Stamp Act Congress resulted in the Declaration of Rights and Grievances , which was the first written expression by representatives of the Americans of many of the rights and complaints later expressed in the United States Declaration of Independence . This included
12183-578: The coast in search of profitable fur trading with local Native American tribes. During the 17th century, Dutch trading posts established for the trade of pelts from the Lenape, Iroquois, and other tribes were founded in the colony of New Netherland . The first of these trading posts were Fort Nassau (1614, near present-day Albany ); Fort Orange (1624, on the Hudson River just south of the current city of Albany and created to replace Fort Nassau), developing into settlement Beverwijck (1647), and into what became Albany; Fort Amsterdam (1625, to develop into
12314-471: The commercial courts are not divisions of other civil courts, but are autonomous ), Switzerland , Austria , Tanzania , Rwanda , Lesotho , South Africa , the British Virgin Islands , St. Lucia , Cayman Islands , Guyana , India , Japan , Malaysia , Thailand , Kenya , Malawi , Saudi Arabia , and Croatia . Use of the term "international commercial court" can also mean
12445-445: The complexity of how a case presents itself procedurally and the processes that will be used to manage a case, rather than by expressly limiting jurisdiction to cases with a specific legal subject matter, as business courts do. California's complex civil litigation program provides an example of defining jurisdiction based on litigation process criteria, such as the presence of large numbers of witnesses, parties, and pre-trial motions, and
12576-563: The courts and parties, while also serving as "a technological laboratory" for later use in all of New York's state courts. The use of technology in case management may be especially apt in international commercial courts, with litigation between parties from different nations. For example, the ADGM Courts in Abu Dhabi self-describe as "the world's first end-to-end, fully digital courts platform...." The history of business and commercial courts in
12707-556: The design, supply and/or installation of computers, computer software and related network and information technology systems and services...." Some jurisdictions emphasized the idea that newly created business courts would make use of cutting edge technologies in handling business litigation, becoming so-called "cyber courts." For example, North Carolina's Business Court was an early proponent of electronic filing and high-tech courtrooms. New York's Commercial Division created "Courtroom 2000" making various technologies available for use by
12838-427: The discussion of constructing seawalls and other coastal barriers around the shorelines of New York City and Long Island to minimize the risk from another such future event. Such risk is considered highly probable due to global warming and rising sea levels . On March 1, 2020, New York had its first confirmed case of COVID-19 after Washington (state) , two months prior. From May 19–20, Western New York and
12969-533: The downstate region's lower elevation, proximity to the Atlantic Ocean, and relatively lower latitude . Upstate New York experiences warm summers, marred by only occasional, brief intervals of sultry conditions, with long and cold winters. Western New York, particularly the Tug Hill region, receives heavy lake-effect snows , especially during the earlier portions of winter, before the surface of Lake Ontario itself
13100-402: The duration of the conflict, and consequently the focus of General George Washington 's intelligence network . On the notorious British prison ships of Wallabout Bay , more American combatants died than were killed in combat in every battle of the war combined. Both sides of combatants lost more soldiers to disease than to outright wounds. The first of two major British armies were captured by
13231-866: The early 1990s, and has expanded greatly in the last thirty years. Business courts (which are often business programs or divisions within existing trial level courts) are operating (as of October 2024) in New York County/Manhattan , and 10 other jurisdictions throughout New York State as the New York Supreme Court Commercial Division, Chicago , North Carolina , New Jersey , Philadelphia and Pittsburgh , Pennsylvania , Reno and Las Vegas , Nevada , Massachusetts , Rhode Island , Maryland , Orlando , Miami , Ft. Lauderdale , and Tampa , Florida , Michigan , Cincinnati , Cleveland and Toledo , Ohio , Iowa , Maine , New Hampshire , Metro Atlanta regionally and statewide via
13362-642: The eastern part of the state, without draining Lakes George or Champlain . Lake George empties at its north end into Lake Champlain, whose northern end extends into Canada, where it drains into the Richelieu River and then ultimately the Saint Lawrence River . The western section of the state is drained by the Allegheny River and rivers of the Susquehanna and Delaware River systems. Niagara Falls
13493-552: The federal government assumed control over immigration. During that period, more than eight million immigrants passed through its doors (two of every three U.S. immigrants). When the federal government assumed control, it established the Bureau of Immigration , which chose the three-acre (1.2 ha) Ellis Island in Upper New York Harbor for an entry depot. Already federally controlled, the island had served as an ammunition depot. It
13624-435: The growth in international commercial courts designed to hear disputes among parties from different nations. Some international commercial courts include foreign judges with commercial court experience on their bench, for example, former Delaware vice chancellor and Supreme Court justice Carolyn Berger serving on Singapore's International Commercial Court. The Business and Property Courts of England and Wales, located in
13755-441: The highest count of any U.S. state in 2022. Many of its landmarks are well known, including four of the world's ten most-visited tourist attractions in 2013: Times Square , Central Park , Niagara Falls , and Grand Central Terminal . New York is home to approximately 200 colleges and universities , including Ivy League members Columbia University and Cornell University , and the expansive State University of New York , which
13886-451: The kind of cases heard in business courts, such as Philadelphia's Complex Litigation Center which only handles mass tort cases. Other complex civil programs expressly include some business and commercial case types within their jurisdiction, along with more numerous non-business court complex case types, such as Connecticut (which includes complex cases involving "formation, governance, dissolution or transfer of control of business entities,"
14017-582: The late 20th century by the federally recognized tribes. New York put up more than 5 million acres (20,000 km ) of former Iroquois territory for sale in the years after the Revolutionary War, leading to rapid development in Upstate New York. As per the Treaty of Paris , the last vestige of British authority in the former Thirteen Colonies —their troops in New York City—departed in 1783, which
14148-449: The need for coordination with other cases (though some categories of case types are deemed provisionally complex). California's complex litigation programs are not statewide, but include at least the following county Superior Courts : Alameda , Contra Costa , Los Angeles , Orange , Riverside , Sacramento , San Francisco , San Mateo , and Santa Clara . Some complex litigation programs do not have any case type overlap with
14279-411: The next century, earning it the nickname of the " Empire State ". Although deindustrialization eroded a portion of the state's economy in the second half of the 20th century, New York in the 21st century continues to be considered as a global node of creativity and entrepreneurship , social tolerance , and environmental sustainability . The state attracts visitors from all over the globe, with
14410-691: The parties may consider mediation, conciliation, or arbitration, Part 27 of the DIFC Court Rules (Dubai) addressing ADR, and the ADGM Courts' court annexed mediation. Some U.S. business courts expressly encourage the use of special masters or referees in expediting some types of decision making during the litigation process, for example in North Carolina, Kentucky, New York, Indiana, Orlando, Ft. Lauderdale, and Georgia. Delaware's Court of Chancery also uses magistrates, who can potentially be final decision makers. The New York Commercial Division and
14541-679: The people for ratification. On July 30, 1777, George Clinton was inaugurated as the first Governor of New York at Kingston. Approximately a third of the battles of the American Revolutionary War took place in New York; the first major one and largest of the entire war was the Battle of Long Island , also known as the Battle of Brooklyn, in August 1776. After their victory, the British occupied present-day New York City, making it their military and political base of operations in North America for
14672-640: The provinces of Ontario and Quebec in Canada, with New York and Ontario sharing the Thousand Islands archipelago within the Saint Lawrence River, while most of its border with Quebec is on land; it shares Lake Champlain with the New England state of Vermont ; the New England state of Massachusetts has mostly a land border; New York extends into Long Island Sound and the Atlantic Ocean , sharing
14803-400: The region. Maritime or shore birds of New York are great blue heron , killdeers , northern cardinals , American herring gulls , and common terns . Reptile and amphibian species in land areas of New York include queen snakes , hellbenders , diamondback terrapins , timber rattlesnakes , eastern fence lizards , spotted turtles , and Blanding's turtles . Sea turtles that can be found in
14934-592: The rest of the State of New York. The placement of a boundary between the two is a matter of great contention. Unofficial and loosely defined regions of Upstate New York include from the Southern Tier, which includes many of the counties along the border with Pennsylvania, to the North Country region, above or sometimes including parts of the Adirondack region. Among the total area of New York state, 13.6% consists of water. Much of New York's boundaries are in water, as
15065-452: The right to representative government . At the same time, given strong commercial, personal and sentimental links to Britain , many New York residents were Loyalists . The Capture of Fort Ticonderoga provided the cannon and gunpowder necessary to force a British withdrawal from the siege of Boston in 1775. New York was the only colony not to vote for independence , as the delegates were not authorized to do so. New York then endorsed
15196-700: The site on March 21, 2014. Upon its completion in 2014, the new One World Trade Center became the tallest skyscraper in the Western Hemisphere, at 1,776 feet (541 m), meant to symbolize the year America gained its independence , 1776. From 2006 to 2018, 3 World Trade Center , 4 World Trade Center , 7 World Trade Center, the World Trade Center Transportation Hub , Liberty Park , and Fiterman Hall were completed. St. Nicholas Greek Orthodox Church and Ronald O. Perelman Performing Arts Center are under construction at
15327-711: The state and [has been] chaired by Robert L. Haig, Esq. [since its inception]." In addition to providing education about the Commercial Division, the CDAC has regularly recommended Commercial Division rule changes that have been adopted after an opportunity for public comment. Indiana's Commercial Courts Working Group evolved into the Commercial Courts Committee which has been intimately involved with developing Indiana's Commercial Court Pilot Program and permanent courts. International examples include, among others,
15458-463: The state are the green sea turtle , loggerhead sea turtle , leatherback sea turtle and Kemp's ridley sea turtle . New York Harbor and the Hudson River constitute an estuary , making the state of New York home to a rich array of marine life including shellfish—such as oysters and clams —as well as fish, microorganisms, and sea-birds. Due to its long history, New York has several overlapping and often conflicting definitions of regions within
15589-487: The state supreme court or trial court level. Georgia created a statewide business court by constitutional amendment. In virtually all cases, the jurisdiction of the court to hear certain cases is limited to disputes that are in some way related to "business" or commercial disputes, and generally fall into two categories: (1) those courts which require that cases have an additional complexity component; and (2) those courts which establish jurisdictional parameters (i) through
15720-445: The state, known as Downstate , encompasses New York City , the United States's largest city; Long Island , the nation's most populous island; and the suburbs and wealthy enclaves of the lower Hudson Valley . These areas are the center of the expansive New York metropolitan area and account for approximately two-thirds of the state's population. The larger Upstate area spreads from the Great Lakes to Lake Champlain and includes
15851-530: The town New Amsterdam , which is present-day New York City); and Esopus (1653, now Kingston ). The success of the patroonship of Rensselaerswyck (1630), which surrounded Albany and lasted until the mid-19th century, was also a key factor in the early success of the colony. The English captured the colony during the Second Anglo-Dutch War and governed it as the Province of New York . The city of New York
15982-467: The two planes. Since September 11, most of Lower Manhattan has been restored. In the years since, over 7,000 rescue workers and residents of the area have developed several life-threatening illnesses, and some have died. A memorial at the site, the National September ;11 Memorial & Museum , was opened to the public on September 11, 2011. A permanent museum later opened at
16113-426: The vast majority of the state's geographic area is dominated by meadows , forests , rivers, farms, mountains, and lakes. Most of the southern part of the state rests on the Allegheny Plateau , which extends from the southeastern United States to the Catskill Mountains ; the section in the State of New York is known as the Southern Tier . The rugged Adirondack Mountains , with vast tracts of wilderness, lie west of
16244-569: Was a major ocean port and had extensive traffic importing cotton from the South and exporting manufacturing goods. Nearly half of the state's exports were related to cotton. Southern cotton factors, planters and bankers visited so often that they had favorite hotels. At the same time, activism for abolitionism was strong upstate, where some communities provided stops on the Underground Railroad . Upstate, and New York City, gave strong support for
16375-475: Was by expensive wagons on muddy roads before canals opened up the rich farmlands to long-distance traffic. Governor DeWitt Clinton promoted the Erie Canal , which connected New York City to the Great Lakes by the Hudson River , the new canal, and the rivers and lakes. Work commenced in 1817, and the Erie Canal opened eight years later, in 1825. Packet boats pulled by horses on tow paths traveled slowly over
16506-589: Was chosen due its relative isolation with proximity to New York City and the rail lines of Jersey City, New Jersey , via a short ferry ride. While the island was being developed and expanded via land reclamation , the federal government operated a temporary depot at the Barge Office at the Battery. Ellis Island opened on January 1, 1892, and operated as a central immigration center until the National Origins Act
16637-638: Was divided roughly in half between the Algonquian Wampanoag and Lenape peoples. The Lenape also controlled most of the region surrounding New York Harbor . North of the Lenape was a third Algonquian nation, the Mohicans . Starting north of them, from east to west, were two Iroquoian nations: the Mohawk —part of the original Iroquois Five Nations, and the Petun . South of them, divided roughly along Appalachia , were
16768-473: Was established in 2005. Since 1996, the Association of Corporate Counsel has endorsed the creation of business courts in the United States where appropriate. In 2023, Texas passed a law creating an appellate level business court, the Fifteenth Court of Appeals, which became operational on September 1, 2024. On August 23, 2024, the Texas Supreme Court upheld the constitutionality of the law creating
16899-552: Was long afterward celebrated as Evacuation Day . New York City was the national capital under the Articles of Confederation and Perpetual Union , the first national government. That organization was found to be inadequate, and prominent New Yorker Alexander Hamilton advocated for a new government that would include an executive, national courts, and the power to tax. Hamilton led the Annapolis Convention (1786) that called for
17030-536: Was passed in 1924, reducing immigration. After that date, the only immigrants to pass through were displaced persons or war refugees . The island ceased all immigration processing on November 12, 1954, when the last person detained on the island, Norwegian seaman Arne Peterssen, was released. He had overstayed his shore leave and left on the 10:15 a.m. Manhattan-bound ferry to return to his ship. More than 12 million immigrants passed through Ellis Island between 1892 and 1954. More than 100 million Americans across
17161-630: Was recaptured by the Dutch in 1673 during the Third Anglo-Dutch War (1672–1674) and renamed New Orange. It was returned to the English under the terms of the Treaty of Westminster a year later. The Sons of Liberty were organized in New York City during the 1760s, largely in response to the oppressive Stamp Act passed by the British Parliament in 1765. The Stamp Act Congress met in
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