7 Critical Updates You Need To Know About The 4th Department Appellate Division In 2025

The New York State Supreme Court, Appellate Division, Fourth Judicial Department, commonly known as the 4th Department Appellate Division, is currently undergoing a significant procedural transformation that impacts attorneys and litigants across its vast 22-county jurisdiction. As of today, December 17, 2025, the most crucial change centers on the complete overhaul of its local rules and the implementation of mandatory electronic filing, signaling a monumental shift toward a fully digitized appellate process.

This intermediate appellate court, seated in Rochester, New York, serves as the final arbiter for thousands of cases originating from the Supreme and County Courts across Central and Western New York. The recent rule changes and a string of high-profile decisions in late 2024 and 2025 underscore the court's ongoing role in shaping New York's legal landscape. Understanding these changes is not just beneficial—it is essential for anyone practicing or appealing within its judicial districts.

The 4th Department Appellate Division: Core Profile and Jurisdiction

The Fourth Judicial Department is one of four intermediate appellate courts in New York State, established to review trial court decisions from the Supreme Court, County Court, Family Court, and Surrogate's Court within its geographic area. The court's primary function is to ensure that legal and procedural errors did not occur in the courts below.

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Key Biographical and Jurisdictional Entities

• Court Name: Supreme Court of the State of New York, Appellate Division, Fourth Judicial Department.
• Location: Rochester, New York.
• Presiding Justice: Hon. Gerald J. Whalen.
• Judicial Districts Covered: Fifth Judicial District, Seventh Judicial District, and Eighth Judicial District.
• Total Counties: 22 counties.
• Role: Hears appeals from trial courts (Supreme and County Courts) and certain specialized courts (Family and Surrogate's Courts) in its jurisdiction.

The 22 Counties Under 4th Department Jurisdiction

The vast jurisdiction of the Fourth Department covers a significant portion of Central and Western New York, including the major metropolitan areas of Buffalo, Rochester, Syracuse, and Utica. This broad reach makes its decisions highly influential.

• Allegany
• Cattaraugus
• Cayuga
• Chautauqua
• Chemung
• Erie
• Genesee
• Jefferson
• Lewis
• Livingston
• Monroe
• Niagara
• Oneida
• Onondaga
• Ontario
• Orleans
• Oswego
• Schuyler
• Seneca
• Steuben
• Wayne
• Wyoming
• Yates

The Rule Revolution: Mandatory E-Filing and the New 22 NYCRR Part 1000

The single most important development affecting practice before the 4th Department Appellate Division is the repeal of its former local rules (the old 22 NYCRR Part 1000) and the enactment of a comprehensive, modern set of rules. This change is part of a broader statewide effort to standardize appellate practice across all four departments, but the Fourth Department's move is a full-scale overhaul.

1. The End of the Old Part 1000 and New Procedural Standards

The court has completely repealed the previous 22 NYCRR Part 1000, which governed practice before the court for years, and has replaced it with a new Part 1000. This action aims to streamline procedures, eliminate ambiguities, and align the Fourth Department's requirements more closely with the uniform statewide appellate rules (22 NYCRR Part 1245). Litigants must now consult the new Part 1000 for all procedural matters, from perfecting an appeal to filing motions.

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2. Mandatory Electronic Filing (E-Filing)

A key component of the new rules is the expansion and, in many cases, the mandating of electronic filing for appeals and motions. This shift means that digital copies of documents must comply with specific technical specifications, fundamentally changing how attorneys interact with the court. The transition is designed to increase efficiency, reduce paper usage, and speed up the appellate process. Practitioners must now familiarize themselves with the technical requirements and the specific rules governing e-filing in the Fourth Department.

3. Emphasis on Uniformity with Statewide Rules

The new local rules are a direct response to the movement toward greater uniformity across New York's four Appellate Departments. By aligning its practices, the Fourth Department reduces the complexity for attorneys who practice in multiple departments, making the entire appellate system more cohesive and predictable. This standardization is a welcome change for the bar, but it requires careful attention to the new language to ensure compliance.

Recent Notable Decisions Shaping Law in Central and Western New York (2025)

The Fourth Department continues to issue thousands of decisions annually, covering the full spectrum of civil and criminal law. The court's 2025 calendar has already produced several significant decisions that illustrate its impact on local jurisprudence and business liability.

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4. Premises Liability and Commercial Negligence

One area of continuous focus for the court is premises liability. The court frequently reviews cases involving slip-and-falls, commercial negligence, and property owner duties. A recent 2025 decision, such as *Richardson v Tops Mkts., LLC*, highlights the court's application of established negligence principles to modern commercial settings and the standards required to prove constructive notice of a dangerous condition. Such decisions dictate the liability standards for businesses across the 22-county region.

5. Digital Age Litigation: Social Media and Privacy

As litigation increasingly involves digital evidence and social media platforms, the Fourth Department is on the front lines of defining the boundaries of discovery and jurisdiction. The court has recently issued decisions addressing these complex issues, including the 2025 case of *Patterson v Meta Platforms, Inc.*, which deals with emerging questions of online platform liability and user data. These rulings are critical for setting precedents in the rapidly evolving landscape of digital law.

Procedural Entities and Topical Authority for Appeals

To successfully navigate the 4th Department, practitioners must master a specific set of procedural entities and key legal concepts. The court’s process involves several distinct stages and filings.

6. Key Procedural Entities and Steps

• Notice of Appeal: The initial document filed in the trial court (Supreme or County Court) to signal the intent to appeal.
• Record on Appeal: The compilation of documents, transcripts, and exhibits from the trial court proceedings, now largely submitted electronically.
• Briefs: The legal arguments prepared by the appellant and respondent, which must strictly adhere to the new formatting and filing rules of the new Part 1000.
• Perfecting the Appeal: The process of submitting all required documents to the Appellate Division within the statutory time limit, a procedure now heavily influenced by e-filing.
• Motion Practice: All requests for relief (extensions, stays, etc.) prior to the argument or decision, which are subject to the revised local rules and mandatory e-filing protocols.

7. The Court of Appeals Connection

The 4th Department Appellate Division is the intermediate court, meaning its decisions are appealable to New York's highest court, the Court of Appeals. The Fourth Department's rulings are frequently reviewed by the Court of Appeals, particularly in cases involving novel legal issues or where a split exists among the four Appellate Departments. Therefore, a decision by the 4th Department is a critical step, but not always the final one, in the New York State court system.