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Nos. 56 & 58
acceptance passed. Accepting this, Supreme Court found that “Seawright was also ill with
COVID-19 symptoms during this time period and was quarantined during the deadlines
(2020 NY Slip Op 31311[U], *4 [Sup Ct, NY County 2020]).
The Appellate Division made a factual finding that petitioner’s “belated filing of a
cover sheet and a certificate of acceptance” were solely attributable “to illness or quarantine
because of the current COVID-19 pandemic,” excluding any other possible cause for the
delay (2020 NY Slip Op 02900 at *2), a finding that respondent Louis Puliafito concedes
in his briefing to us. Of course, we are bound by and may not review that factual
determination (Buchanan v Espada, 88 NY2d 973, 975 [1996]). Instead, our task is to
consider petitioner’s belated filings in light of the unique and unprecedented circumstances
wherein the truncated filing deadlines were in potential conflict with official public health
directives and quarantine guidelines.
The purpose of Chapter 24 was undeniably to mitigate the spread of COVID-19 and
was part and parcel of an aggressive government response based on the determination that
individuals manifesting symptoms should stay home and away from other people as much
as possible. The truncated political calendar was not meant to force petitioner to meet the
Election Law’s filing deadlines when she was sick and complying with quarantine
directives that made her unable to complete the filing without running afoul of the
government guidance. Indeed, as an elected official tasked with promoting the
government’s response to the serious and deadly public health crisis afflicting New York,
and finding herself to be symptomatic, petitioner was faced with the inherent tension in the
new, compressed electoral filing timeframe and the government’s guidance to avoid
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