Can a plaintiff bring a civil action for violation of section 18 of the New York State Criminal Code?

MultiRegion, United States of America

The following excerpt is from Banuelos v. Gabler, Case No. 1:18-cv-00675-LJO-SAB (E.D. Cal. 2018):

Plaintiff cannot bring a civil suit for violation of these sections of Title 18 as they do not provide for a private right of action. See Salem v. Arakawa, No. CV 15-00384 LEK-KSC, 2016 WL 1043050, at *6 (D. Haw. Mar. 15, 2016) ("It is well-established that 'Plaintiffs, as private citizens, lack standing to bring claims under criminal statutes.' ").

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