In People v. Beeney, 181 Misc 2d 201, 204, 694 NYS2d 583 [Monroe County Ct 1999]) the court noted that, at that time, no "published or unpublished New York State court decisions interpreting the statute" could be found.
The court further noted, however, that many states "have statutes that regulate the minimum speed limits and, indeed, several States use virtually identical language to New York's Vehicle and Traffic Law § 1181 (a)," and that "there are ... a few published decisions of sister-State jurisdictions which provide guidance." (Id.)
After reviewing these decisions, the court concluded that there are three elements to this statute, to wit: (1) operation of a motor vehicle below the speed limit, (2) which operation impedes the "normal and reasonable movement of traffic" and (3) "creates a clear, present and real danger." (Beeney at 203, 207.)