Justia New York Court of Appeals Opinion Summaries

The Court of Appeals affirmed the judgment of the appellate division reversing the decision of Supreme Court granting Plaintiffs summary judgment and enjoining enforcement of New York City Administrative Code 10-181, which makes criminal the use of certain restraints by police officers during an arrest, holding that Administrative Code 10-181 does not violate the New York Constitution on either preemption or due process grounds.After Administrative Code 10-181 became law Plaintiffs - law enforcement unions - commenced this action seeking a declaration that the local law was unconstitutional because it was field and conflict preempted by a combination of state laws and that it was void for vagueness and seeking to enjoin the law's enforcement. Supreme Court granted summary judgment for Plaintiffs and enjoined enforcement of section 10-181. The appellate division reversed. The Court of Appeals affirmed, holding (1) section 10-181 was a valid exercise of the City's municipal law-making authority because the legislature has not preempted the field; and (2) Plaintiffs were not entitled to relief on their vagueness challenge. View "Police Benevolent Ass'n of City of New York, Inc. v. City of New York" on Justia Law

The Court of Appeals affirmed Defendant's convictions of two counts of murder in the first degree and two counts of murder in the second degree, holding that the admission of two autopsy reports through an expert witness who did not perform the autopsies, combined with that witness's testimony, violated Defendant's constitutional right to confrontation, but the error was harmless.Defendant was convicted of murdering the two young children in her care by repeatedly stabbing them. The Court of Appeals affirmed the convictions, holding (1) People v. Freycinet, 11 NY3d 38 (NY 2008), should no longer be followed because it is inconsistent with the demands of the Confrontation Clause as recently articulated by the Supreme Court; and (2) Defendant's constitutional right to confrontation was violated by the admission of the autopsy reports and the testimony of the witness at issue, but the error was harmless beyond a reasonable doubt. View "People v. Ortega" on Justia Law

The Court of Appeals reversed the decision of the appellate division affirming Defendant's convictions for second degree robbery and petit larceny, holding that admission of a criminalist's testimony and underlying exhibits was error, and the error was not harmless, thus entitling Defendant to a new trial.On appeal, the appellate division ruled that Defendant's constitutional right to confrontation was not violated when the criminalist performed his own analysis about the creation of DNA profiles. The Court of Appeals disagreed and reversed, holding that because the record failed to establish that the testifying analyst had the requisite involvement with the DNA profiles the admission of the criminalist's testimony and underlying exhibits was erroneous, and the People did not establish that there was no reasonable possibility that the error might have contributed to Defendant's conviction. View "People v. Jordan" on Justia Law

The Court of Appeals affirmed the order of the appellate division affirming the judgment of Supreme Court denying Defendant's motion to suppress the firearm found in the vehicle he was driving, holding that the People sustained their burden of demonstrating that the inventory search protocol in this case met "the constitutional minimum."Two New York Police Department officers observed Defendant commit multiple traffic infractions while driving, stopped him, and arrested him for carrying a gravity knife in his pocket. At the precinct, the officers conducted an inventory search of the vehicle and recovered a firearm from the truck. Defendant filed a motion to suppress the firearm on the grounds that the NYPD's inventory search protocol was unconstitutional. The motion was denied, and Defendant pled guilty to criminal possession of a firearm. The Court of Appeals affirmed, holding that Defendant failed to overcome the People's proof establishing a valid inventory search protocol. View "People v. Douglas" on Justia Law

The Court of Appeals held that the legislature's grant of rulemaking authority to the Commission on Forensic Sciences was sufficient to authorize the Commission's promulgation of the Familial DNA Search (FDS) Regulations codified at 9 N.Y.C.R.R. 6192.1 and 6192.3.In 2017, the DNA Subcommittee submitted to the Commission a recommendation to authorize familial DNA searches. The Commission adopted the recommendation, and the New York State Division of Criminal Justice Services (DCJS) formally adopted the recommendation as part of the FDS Regulations. Petitioners brought this N.Y. C.L.P.R. 78 proceeding arguing that Respondents lacked statutory authority to promulgate the FDA Regulations, therefore violating the New York Constitution's separation of powers doctrine. Supreme Court denied the petition on the merits, and the appellate division affirmed. The Court of Appeals reversed, holding that the Commission had the statutory authority to promulgate the FDS Regulations. View "Stevens v. N.Y. State Division of Criminal Justice Services" on Justia Law

The Court of Appeals reversed the order of the trial court applying New York's Rape Shield Law, N.Y. C.P.L. 60.42, to exclude forensic evidence proffered by Defendant to demonstrate that that the evidence the prosecution was seeking to attribute to him was consistent with masturbation or sexual contact with a third-party, holding that the trial court erred in applying the Rape Shield Law in this case, depriving Defendant of his constitutional right to present a defense.Defendant was charged with two counts of first-degree sexual abuse arising from allegations that he digitally penetrated his minor relative's vagina and fondled her breasts. The jury convicted Defendant of the sexual abuse charge related to the alleged digital penetration of the complainant's vagina. The appellate division affirmed. The Court of Appeals affirmed, rejecting Defendant's argument that the trial court improperly excluded the forensic evidence under CPL 60.42. The Court of Appeals reversed, holding that the trial court's exclusion of the forensic evidence at issue deprived Defendant of a meaningful opportunity to present a complete defense. View "People v. Cerda" on Justia Law

The Court of Appeals affirmed the order of the appellate division reversing Supreme Court's conclusion that the application of the Sexual Assault Reform Act (SARA) to Petitioner violated the Ex Post Facto Clause of the federal Constitution when applied to offenders whose crimes predated the 2005 amendments to the Act, holding that the effect of SARA's school grounds condition, as codified in N.Y. Exec. Law 259-c(14), was not punitive.In 1986, Petitioner was convicted of two counts of murder in the second degree and other crimes. Petitioner was unable to locate SARA-compliant housing before his open release date and therefore remained in custody until he could locate suitable housing under SARA's school grounds condition prohibiting him from living within 1,000 feet of a school. Petitioner filed a petition for a writ of habeas corpus arguing that SARA's residency restriction violated ex post facto principles. Supreme Court granted Petitioner's application and ordered his release. The appellate division reversed. The Court of Appeals affirmed, holding that the condition does not violate the Ex Post Facto Clause. View "People ex rel. Rivera v. Superintendent, Woodbourne Correctional Facility" on Justia Law

The Court of Appeals reversed the conclusion of the appellate division that the Sex Offender Registration Act (SORA) court acted within its discretion by upwardly departing to level three in determining Defendant's risk level classification, holding that the SORA court deprived Defendant of basic due process protections of notice and an opportunity to be heard.Defendant's convictions required him to register under SORA. At the SORA hearing, the court noted that Defendant would normally be required to register as a level two sex offender but upwardly departed to level three due to Defendant's "extensive prior disciplinary history." The appellate division affirmed. The Court of Appeals reversed, holding that the proceeding failed to comport with due process because Defendant was provided no notice or meaningful opportunity to be heard in response to the District Attorney's request for an upward departure. View "People v. Worley" on Justia Law

The Court of Appeals affirmed the judgment of the appellate division affirming the judgment of Supreme Court denying the County of St. Lawrence's action seeking a declaratory judgment that Local Law No. 2-2021 of the City of Ogdensburg was inconsistent with N.Y. Real. Prop. Tax Law (RPTL) 1150 or otherwise unconstitutional under the home rule article of the New York State Constitution, holding that there was no error.The law at issue in this case repealed a prior local law validly opting out of the application of RPTL article 11. The County commenced this proceeding arguing that the law was not in accord with state law and impaired the rights of the County and the County Treasurer. Supreme Court denied the petition and declared the law to be valid and enforceable. The appellate division affirmed. The Court of Appeals affirmed, holding that the law did not violate the statutory and constitutional protections at issue in this case but effectuated a power granted by the legislature to cities wishing to revoke their opt-out from article 11. View "St. Lawrence County v. City of Ogdensburg" on Justia Law

The Court of Appeals reversed the order of the appellate division affirming Defendant's conviction, following a jury trial, of second-degree murder and second-degree weapon possession, holding that Defendant's Sixth Amendment right to a public trial was violated in this case and that Defendant was entitled to a new trial.For the last four days of Defendant's eight-day jury trial, which included the testimony of several witnesses, summations, and the jury's verdict, the trial court ordered the courtroom closed to the public and all interested spectators. At the conclusion of trial the jury found Defendant guilty. The appellate division affirmed. The Court of Appeals reversed and remanded the case for a new trial, holding that the record did not demonstrate that "unusual circumstances" necessitated closure of the courtroom, and therefore, the trial court improperly abridged Defendant's constitutional right to a public trial. View "People v. Reid" on Justia Law