Justia New York Court of Appeals Opinion Summaries

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The three respondents in these cases had been diagnosed with antisocial personality disorder (ASPD) and other conditions, diseases, and/or disorders. The State brought Mental Hygiene Law article 10 proceedings against each respondent. Respondents argued that the Court of Appeals’ holding in State v. Donald DD warranted the dismissal of the petitions brought against them. In Donald DD, that Court held that, in a trial conducted pursuant to article 10, evidence that a respondent suffers from ASPD cannot be used to support a finding that he has a mental abnormality as defined by Mental Hygiene Law 10.03(i) “when it is not accompanied by any other diagnosis of mental abnormality.” The Court of Appeals rejected Respondents’ arguments, holding that in each of the article 10 proceedings, the evidence was sufficient to support the verdicts that Respondents suffered from a “mental abnormality” as defined in the Mental Hygiene Law. View "State v. Dennis K." on Justia Law

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Janice Mazella (Plaintiff) filed this medical malpractice and wrongful death action against Dr. William Beals (Defendant), alleging that Defendant’s substandard medical treatment of her husband proximately caused his suicide. The jury returned a verdict for Mazella, finding that Defendant’s negligence proximately caused the decedent’s suicide. The Court of Appeals reversed and ordered a new trial, holding (1) the evidence was sufficient to support the verdict; but (2) the trial court abused its discretion in admitting evidence concerning Defendant’s negligent treatment of twelve other patients because the evidence was irrelevant to Defendant’s liability and unduly prejudiced the jury. View "Mazella v. Beals" on Justia Law

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Plaintiff filed an action alleging that Defendants committed fraud and negligence when performing and evaluating a random drug test that Plaintiff was required to take as an airline pilot. The United States Court of Appeals for the Second Circuit certified two questions of New York law to the New York Court of Appeals. The Court accepted the questions and answered (1) drug testing regulations and guidelines promulgated by the Federal Aviation administration and the Department of Transportation do not create a duty of care for drug testing laboratories and program administrators under New York negligence law; and (2) a plaintiff may not establish the reliance element of a fraud claim under New York law by showing that a third party relied on a defendant’s false statements resulting in injury to the plaintiff. View "Pasternack v. Lab. Corp. of Am. Holdings" on Justia Law

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Starting during World War II, Crane sold valves to the Navy for use in high-pressure, high-temperature steam pipe systems. Crane's valves did not contain asbestos, but could not practically function in such systems without gaskets, insulation and packing. Crane's technical drawings specified the use of asbestos-based sealing components. Crane packaged the Navy’s valves with asbestos gaskets and stem packing. Navy specifications called for gaskets, valves and insulation that contained asbestos. Crane also marketed "Cranite," an asbestos-based sheet material for use in producing replacements for the original gaskets and packing. Starting in the 1930s, trade associations to which Crane belonged, issued publications describing the hazards of exposure to dust from asbestos-based products. In the 1960s, one group published an article summarizing the growing evidence of a connection between asbestos exposure and mesothelioma. Until at least 1980, Crane never provided warnings. In a suit on behalf of a Navy technician, diagnosed with mesothelioma, the court instructed the jury on the duty to warn against latent dangers resulting from foreseeable uses of its product of which the manufacturer knew or should have known, and on causation, stating that any presumption that the technician would have heeded warnings was rebuttable. The jury found Crane 99% liable and awarded $32 million in damages. The New York Court of Appeals affirmed. The manufacturer has a duty to warn of the danger arising from the known and reasonably foreseeable use of its product in combination with a third-party product which, as a matter of design, mechanics or economic necessity, is necessary to enable the manufacturer's product to function as intended. The court noted proof of Crane's affirmative steps to integrate its valves with third-party asbestos-laden products. View "In re: New York City Asbestos Litig." on Justia Law

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Defendant pleaded guilty to incest in the third degree. Prior to Defendant’s release from incarceration, the Board of Examiners of Sex Offenders recommended that Defendant be classified as risk level three sex offender. The Sex Offender Registration Act (SORA) court assessed Defendant points under risk factors one, five, and nine and adjudicated Defendant a risk level three sex offender. The Appellate Division affirmed, concluding that the record supported the SORA court’s risk-level classification. The Court of Appeals affirmed, holding that the People proved facts to support Defendant’s SORA risk-level classification by clear and convincing evidence. View "People v. Sincerbeaux" on Justia Law
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In these three consolidated appeals, the Court of Appeals considered whether the trial courts abused their discretion in precluding cross-examination into allegations of a law enforcement officer’s prior misconduct made in an unrelated federal lawsuit. The Court of Appeals applied well-established rules governing the use of this type of impeachment material to the specific facts of these cases and affirmed the orders of the Appellate Division in two cases and reversed in the third case, holding that law enforcement witnesses should be treated in the same manner as any other prosecution witness for purposes of cross-examination. View "People v. Smith" on Justia Law
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The case stemmed from a dispute over property subject to the terms of a will executed by a now-deceased member of the Tonawanda Seneca Nation (the Nation). Judge Robert Noonan, a county court and surrogate’s court judge, presided over the proceedings seeking to probate the will in the surrogate’s court. The Nation commenced a N.Y. C.P.L.R. 78 proceeding in the Appellate Division seeking to prohibit the judge or any future surrogate in the estate proceeding from exercising jurisdiction over the case. The Appellate Division dismissed the petition for lack of jurisdiction, concluding that the proceeding must originate in Supreme Court. At issue on appeal was whether the proceeding must originate in Supreme Court because Judge Noonan’s position as Surrogate was not one listed in N.Y. C.P.L.R. 506(b)(1), which limits article 78 proceedings that may be commenced in the Appellate Division to those against County Court Judges and Supreme Court Justices, or whether Judge Noonan’s position as a county court judge required that the proceeding be commenced in the Appellate Division. The Court of Appeals affirmed, holding that, where Judge Noonan was acting as Surrogate with respect to the probate of the will, the Nation’s suit challenging those actions should have been brought in Supreme Court. View "Tonawanda Seneca Nation v. Noonan" on Justia Law

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After a jury trial, Defendant was convicted of two counts of criminal possession of a controlled substance in the third degree. The county court sentenced Defendant, as a second felony offender, to concurrent terms of eight years’ imprisonment and three years of postrelease supervision. On appeal, Defendant argued that the county court erred in failing to hold a Darden hearing, as the information provided by a confidential informant (CI) was insufficient to establish probable cause to support a search warrant for his apartment. The Appellate Division affirmed. The Court of Appeals affirmed, holding that a Darden hearing was unnecessary because reasonable cause for the search existed independently of the statements by the CI to the police. View "People v. Crooks" on Justia Law

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Defendants in these two cases were convicted of criminal offenses in local courts. The courts were not designated by law as a court of record and did not have a court stenographer present during the proceedings. Defendants filed a notice of appeal and provided as the record a transcript produced from an electronic recording device employed by the court to record the trial proceedings. Defendants did not file an affidavit of errors. The People moved for dismissal, arguing that Defendants’ failure to file an affidavit of errors pursuant to N.Y. Crim. Proc. Law 460.10 was a jurisdictional defect. The intermediate appellate courts come to opposite conclusions as to whether Defendants properly took their appeals within the meaning of N.Y. Crim. Proc. Law 460.10. The Court of Appeals reversed in one case and affirmed in the other, holding that, in accordance with the controlling statute, an affidavit of errors is a jurisdictional prerequisite for taking an appeal from a local criminal court where there is no court stenographer. View "People v. Smith" on Justia Law
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Defendant was indicted on charges of identity theft in the first degree, criminal possession of stolen property in the fourth degree, and theft of services. At several court appearances, the People requested adjournments. Defendant moved to dismiss the indictment based on a violation of his statutory speedy trial rights. Supreme Court denied the motion. More than sixteen months after commencement of the criminal action, Defendant was convicted as charged. The Appellate Division modified the judgment by dismissing the identity theft count but otherwise affirmed. The Court of Appeals reversed, holding that Defendant was entitled to dismissal of the indictment on speedy trial grounds, as (1) Defendant did not consent to additional delay attributable to court congestion, and (2) the People failed to announce readiness within the statutory time period. View "People v. Barden" on Justia Law