This Wiley Rein LLP memorandum reports on a recent New York federal district court decision (Bell Atlantic Mobile of Rochester v. Town of Irondequoit, No. 11-CV-6141 (W.D.N.Y. Jan. 31, 2012)). The case is one of the first to apply the Federal Communications Commission's (FCC's) 2009 Shot Clock Order since the order was upheld by the Fifth Circuit Court of Appeals. In its order, the FCC sought to promote wireless infrastructure development and end application processing delays by local governments.