Justia New York Court of Appeals Opinion Summaries

In 2003, School District announced to its faculty and staff, who were represented by Union, that the district's practice of reimbursing Medicare Part B premiums of retirees sixty-five years or older would be terminated. Union filed a contract grievance, alleging that School District violated the collective bargaining agreement (CBA) between the parties by failing to negotiate cancellation of Medicare Part B premium reimbursement. After a hearing, an arbitrator concluded that the district was not contractually obligated to reimburse Medicare Part B premiums. The Union also filed an improper practice charge with the New York State Public Employment Relations Board (PERB). An ALJ concluded that School District had violated N.Y. Civ. Serv. Law 209-a(1) because the district promised in the past to reimburse current employees' post-retirement Medicare Part B premiums. PERB denied the district's exceptions and affirmed the ALJ. The Court of Appeals affirmed, holding (1) it was reasonable for PERB not to defer to the arbitrator's findings relating to past practice; (2) PERB's decision in regard to past practice was supported by substantial evidence; and (3) the continued Medicare Part B premium reimbursement was not unconstitutional. View "Chenango Forks Cent. Sch. Dist. v. State Pub. Employee Relations Bd." on Justia Law

Defendant was charged with sex-related crimes. In his summation, defense counsel argued that parts of Complainant's testimony were incredible because a statement Complainant gave to a police officer who responded to her 911 call omitted a number of details that were in Complainant's later testimony and that the People should have called the officer to testify. The trial court directed the jury to disregard counsel's missing witness argument. After summations, defense counsel moved for a mistrial on the basis of this ruling. The court denied the motion, stating that counsel should have asked for a missing witness instruction if he wanted to make a missing witness argument. Defendant was then convicted of criminal sexual act, criminal contempt, and assault. The Appellate Division affirmed, concluding that there was no "good faith basis" for comment by defense counsel on the People's failure to call the officer. The Court of Appeals affirmed, holding that the trial court erred in prohibiting Defendant from making a missing witness argument but that the error was harmless. View "People v. Thomas" on Justia Law

Defendant was arrested for robbery. An attorney from the Legal Aid Society represented Defendant at trial. Prior to opening statements, defense counsel alerted the court to a possible conflict of interest arising from counsel's previous representation of Franklin DeJesus, whom it was rumored to have committed the robbery. After internal discussions with the trial judge, defense counsel proceeded with the case. The jury found Defendant guilty of first-degree robbery. After Defendant's conviction, Legal Aid moved to set aside the verdict based on newly discovered evidence consisting of DeJesus' alleged jailhouse confession to Defendant. Supreme Court denied the motion. The Appellate Division affirmed, determining that Defendant had not been deprived of his right to effective legal assistnce due to Legal Aid's dual representation of Defendant and DeJesus because there was no conflict between their interests. The Court of Appeals affirmed, holding that Defendant did not adequately demonstrate that he received less than meaningful representation, as the record did not establish that the potential conflict actually affected the presentation of the defense or otherwise impaired counsel's performance. View "People v. Sanchez" on Justia Law

Defendant was charged with intentional murder and second-degree weapon possession. Defendant's first trial resulted in a hung jury and mistrial. Defendant was re-tried, and the jury convicted Defendant as charged. After the jury verdict was handed down, the presiding judge, Justice Carter, issued an order recusing himself because of his discovery that he knew the uncle of the victim. In the meantime, Defendant filed a motion seeking an order granting his prior applications for a trial order of dismissal. Justice Palmieri, the judge to whom the case was reassigned, denied Defendant's motion. Defendant appealed, arguing that the evidence was legally insufficient to prove his guilt and that N.Y. Judiciary Law 21 barred any other judge than Justice Carter from deciding his motion. The Appellate Division affirmed. The Court of Appeals affirmed, holding (1) legally sufficient evidence supported Defendant's convictions; and (2) Judiciary Law 21 did not bar Justice Palmieri from ruling on the motion at issue. View "People v. Hampton" on Justia Law

After a trial, Defendant was convicted of murder in the second degree. Defendant appealed, challenging his custodial interrogation that lasted almost fifty hours. Defendant's previously filed motion to suppress was granted to the extent of excluding the statements Defendant made during the "marathon interrogation." On appeal, Defendant argued that his suppression motion should have been granted not only to the statements made during the interrogation itself but to the further extent of suppressing his subsequent inculpatory statements. The appellate division held that Defendant's subsequent statements, which were made approximately ten hours after the lengthy interrogation were sufficiently attenuated from the prior interrogation to conclude that they were not the product of official compulsion. The Court of Appeals reversed and ordered a new trial, holding that, as a matter of law, the taint of the wrongful police action was not attenuated. View "People v. Guilford" on Justia Law

The Empire Zones Program Act offered state tax incentives designed to enhance business development in the state. In 2009, the program was amended to introduce two new criteria businesses must meet to retain their certificates for the program. Plaintiffs were five businesses which were certified under the program prior to 2008. In 2009, Plaintiffs were decertified from the program for failing to meet the new criteria. Supreme Court granted summary judgment for the James Square plaintiffs, concluding that the state defendants acted without legal authority when they applied the new criteria for the program retroactively. The legislature subsequently clarified its intention, stating that the 2009 amendments to the program were to be applied retroactively to January 1, 2008. Supreme Court adhered to its prior determination, declaring that the legislature's clarification as applied was unconstitutional. The Appellate Division affirmed. Regarding the additional plaintiffs, the Appellate Division modified Supreme Court's holding to the extent of granting Plaintiff's petitions seeking a declaration that the 2009 amendments could not be applied retroactively to January 1, 2008. The State appealed. The Court of Appeals affirmed the Appellate Division's determinations in all five cases that the 2009 amendments should not be applied retroactively. View "James Square Assocs. LP v. Mullen" on Justia Law