State v. Monteleone

In State v. Monteleone, 138 A.D.2d 821 (3rd Dept. 1988), the Court refused to apply the definition of a consumer credit transaction to a not-for-profit hospital operated by a state agency. The Court in that case noted that "we are not considering the more general question of whether providing medical services can be considered a consumer credit transaction" and pointed to the Ratner v. Drucker case for one side of the argument and the 1974 Opinion of the Attorney General 180 (which held that medical and similar services are within the ambit of the statutory definition) for the opposing view.