Justia New York Court of Appeals Opinion Summaries

Plaintiffs challenged the facial constitutionality of N.Y. Pub. Health Law 2808(5)(c), which prohibits the withdrawal or transfer of residential health care facility equity or assets in amount exceeding three percent of the facility's most recently reported annual revenue from patient care services without the prior approval of the State Commissioner of Health. Plaintiffs in this case were concerned that the challenged provision would negatively impact nursing homes. Supreme Court granted summary judgment to Plaintiffs, concluding that the statute impermissibly ceded legislative policymaking power to a regulatory agency situated in the executive branch and infringed on the substantive due process property interests of facility owners. The Appellate Division affirmed. The Court of Appeals reversed, holding (1) the lower courts erred in concluding that the statute was offensive to substantive due process; and (2) the statute does not improperly delegate legislative policy-making power. View "Brightonian Nursing Home v. Daines" on Justia Law

Plaintiff, an employee of a commercial cleaning company, was injured after falling from a ladder while providing janitorial services for a retail store. Plaintiff was dusting a display shelf when he fell. Plaintiff brought an action under N.Y. Lab. Law 240(1) against the retail store and the building owner. Supreme Court granted summary judgment for Defendants, concluding that the statute did not apply to workers employed on a daily basis to conduct routine commercial cleaning, such as the dusting, sweeping, mopping, and general tidying that Plaintiff was engaged in at the time of his injury. The Appellate Division affirmed. The Court of Appeals affirmed, holding that Plaintiff was not engaged in an activity that fell within the purview of Labor Law 240(1) at the time of his injury. View "Soto v. J. Crew Inc." on Justia Law

After a jury trial, Defendant was convicted of the offense of manslaughter. The Appellate Division affirmed. At issue on appeal was whether Defendant's trial counsel was ineffective for failing to use a peremptory challenge to remove a juror who was a long-time friend of the prosecuting attorney. The Court of Appeals affirmed, holding that counsel's decision not to use a peremptory challenge on the juror was questionable, but the mistake, if it was one, was not the sort of egregious and prejudicial error that rendered counsel's representation of Defendant as a whole ineffective, and thus, Defendant was not deprived of his constitutional right to counsel. View "People v. Thompson" on Justia Law

Defendant, a patient in the psychiatric ward of a medical center, was convicted of assault in the first and second degree based on an incident in which he assaulted and severely injured another psychiatric patient. The Appellate Division modified by vacating the second degree assault conviction and, as modified, affirmed. The Court of Appeals affirmed, holding that Supreme Court did not deny Defendant his constitutional right to present a defense, to confront witnesses, and to a fair trial by limiting Defendant's examination of two witnesses - a doctor who evaluated Defendant after the assault and the assault victim's father. View "People v. Daryl H." on Justia Law

After a jury trial, Defendant was convicted of intentional murder and second-degree weapon possession. On appeal, Defendant argued that the trial judge committed mode of proceedings errors by departing from the protocol for handling jury notes set forth in People v. O'Rama. The Appellate Division affirmed the conviction and sentence, determining that Defendant's unpreserved claims did not implicate O'Rama or constitute mode of proceedings errors and declining to reach them in the interest of justice. The Court of Appeals affirmed, holding that Defendant's claims were unpreserved and unreviewable and did not constitute mode of proceedings errors. View "People v. Alcide" on Justia Law

Respondent was convicted of second degree forgery and sentenced to a term of probation. One of the conditions of Respondent's probation was a requirement that he submit to random drug testing. Appellant, a drug testing laboratory, was engaged by the County to conduct the testing. After Appellant detected the presence of THC in Respondent's fluid sample, Respondent's probation was revoked. Respondent subsequently commenced this action alleging that Appellant had issued the report reflecting the positive test result both negligently and as part of a policy of deliberate indifference to his rights. Supreme Court granted Appellant's motion to dismiss for failure to state a cause of action. The Appellate Division reversed, concluding that the complaint stated a cause of action against Appellant for the negligent testing of Respondent's biological specimen notwithstanding the absence of a contractual relationship between the parties. The Court of Appeals affirmed, holding that Appellant owed a duty to Respondent under these circumstances. View "Landon v. Kroll Lab. Specialists, Inc." on Justia Law