Justia New York Court of Appeals Opinion Summaries

At issue in this case was whether the three-and-a-half year retroactive application of the 2010 amendments to N.Y. Tax Law 632(a)(2) were unconstitutional as applied to Plaintiffs under the due process clauses of the federal and state constitutions. Plaintiffs, Florida residents, brought this action claiming that the 2010 amendments retroactively imposed a tax on the 2007 sale of the stock of their subchapter S corporation in a deemed asset sale, for which they utilized the installment method of accounting for federal tax purposes, and seeking a declaration that the application of the amendments was unconstitutional as applied to them. Supreme Court granted summary judgment for Defendants, determining that the amendments were curative and, because Plaintiffs failed to show reasonable reliance on any relevant pre-amendment law, retroactive application of the statute was justified. The Appellate Division reversed. The Court of Appeals reversed, holding that retroactive application of the 2010 amendments did not violate Plaintiffs’ due process rights. View "Caprio v. New York State Dept. of Taxation & Fin." on Justia Law

After a jury trial, Defendant was convicted of second degree intentional murder. Defendant was sentenced to a term of twenty-five years to life. The Appellate Division affirmed, concluding that the evidence was legally sufficient, that Defendant was not denied meaningful representation, and that Defendant’s claim of prosecutorial misconduct committed during summation was unpreserved. The Court of Appeals reversed, holding (1) defense counsel was ineffective for failing to object when the prosecutor misrepresented to the jury critical DNA evidence as proof of Defendant’s guilt in contradiction of the People’s expert testimony; and (2) Defendant was denied a fair trial as a result. View "People v. Wright" on Justia Law

Defendant pleaded guilty to manslaughter in the first degree and gang assault in the first degree. After a plea colloquy, the court accepted the plea, and Defendant was sentenced to a term of imprisonment. Defendant appealed, arguing that the County Court erred in denying in part his motion to suppress statements he made to police. The Appellate Division affirmed, concluding that Defendant’s valid waiver of the right to appeal barred his challenge to the court court’s suppression ruling. The Court of Appeals affirmed, holding that Defendant knowingly and intelligently waived his right to appeal, and therefore, he was precluded from challenging the County Court’s adverse suppression ruling. View "People v. Sanders" on Justia Law

In 2009, Defendant pleaded guilty in a Westchester County court to criminal possession of a forged instrument in the third degree. In 2010, a Suffolk County Grand Jury charged Defendant with criminal possession of a forged instrument in the second degree. Defendant moved to dismiss the Suffolk County charges on statutory double jeopardy grounds, arguing that his second prosecution was based on the same criminal transaction as the previous prosecution. The court denied the motion. The Appellate Division affirmed, holding that the crimes for which Defendant was prosecuted in Suffolk County were not based upon the same criminal transaction as the crime for which he was prosecuted in Westchester County. The Court of Appeals affirmed, holding that the successive prosecutions here involved two different criminal transactions. View "People v. Lynch" on Justia Law

A law enforcement officer stopped Defendant’s vehicle based on the officer’s mistaken belief that Defendant violated the Vehicle and Traffic Law. Defendant was subsequently charged with failing to stop at a stop sign and driving while intoxicated. Defendant moved to suppress the evidence, arguing that the officer lacked probable cause for the initial stop. The county court suppressed the evidence, concluding that the traffic stop was improper. The Court of Appeals reversed, holding that that traffic stop was justified based on the officer’s reasonable belief that Defendant failed to stop at a valid stop sign. View "People v. Guthrie" on Justia Law

At issue in this criminal case was the prosecution’s references in its case-in-chief to Defendant’s selective silence during custodial interrogation, after Defendant had waived his Miranda rights and agreed to speak to the police. After a jury trial, Defendant was convicted of sexual abuse in the first degree, rape in the third degree, and criminal impersonation in the first degree. The Appellate Division affirmed as modified, holding that the comments by the prosecutor during opening and closing statements concerning Defendant’s post-arrest silence were improper, and the county court erred in admitting into evidence a portion of a law enforcement officer’s testimony concerning Defendant’s selective silence, but any errors were harmless beyond a reasonable doubt. The Court of Appeals reversed, holding (1) as a matter of state evidentiary law, evidence of a defendant’s selective silence generally may not be used by the People as part of their case-in-chief either to allow the jury to infer the defendant’s admission of guilt or to impeach the credibility of the defendant’s version of events when the defendant has not testified; and (2) the error in this case was not harmless. View "People v. Williams" on Justia Law

After a jury trial, Defendant was convicted of depraved indifference murder, intentional murder on a transferred intent theory, attempted murder in the second degree, and criminal possession of a weapon in the second degree. The convictions arose from a single homicide where Defendant killed one victim in the course of attempting to kill someone else. Defendant appealed, arguing that the trial court violated his due process rights when it submitted to the jury depraved indifference murder and intentional murder on a “transferred intent” theory in the conjunctive with respect to the same victim. The Court of Appeals modified the order of the Appellate Division and ordered a new trial on the intentional murder, depraved indifference murder, and attempted murder counts, holding (1) a defendant cannot be convicted of depraved indifference murder and intentional murder on a transferred intent theory in a case involving the death of the same person, and therefore, the trial court erred in submitting to the jury both charged in the conjunctive rather than in the alternative; and (2) the trial court violated Defendant’s Sixth Amendment right to confrontation by admitting into evidence certain grand jury statements of a non-testifying witness. View "People v. Dubarry" on Justia Law

Two codefendants (Defendants) were convicted of second-degree murder for acting in concert with three others to kill Matharr Cham. When the People’s main witness failed to appear twice during trial, the court held an in camera, off-the-record discussion with the witness to ascertain the witness's mental and physical ability to testify. The proceeding was held without counsel present. The Court of Appeals affirmed, concluding that Defendants’ right to counsel was not violated. The Court of Appeals reversed the orders in each case and remitted for new trials, holding that the trial court violated Defendants’ right to counsel by denying defense counsel access to the proceeding because, under the facts of this case, the witness's mental and physical health were inextricably tied to his credibility, a nonministerial issue for trial. View "People v. Carr" on Justia Law

After two separate jury trials in two unrelated cases, Defendants were convicted of manslaughter in the first degree and murder in the second degree, respectively. Defendants appealed, arguing that the introduction of purported “background and narrative” evidence through the testimony of police detectives violated their right to confrontation. The Appellate Division in both cases affirmed. The Court of Appeals affirmed in one case and reversed in the other, holding (1) the trial court in the first case erred in admitting the testimony because it exceeded the permissible bounds of providing background information, and the error was not harmless where there was no proper curative or limiting charge given to temper the testimonial evidence; and (2) the statement made in the second case was not testimonial, and therefore, there was no merit to Defendant’s contention that his confrontation rights were violated. View "People v. Garcia" on Justia Law

After a jury trial, Defendant was convicted of criminal possession in the first degree. Defendant appealed, arguing, among other claims, that his right to counsel was violated when the trial court replaced a sick juror with an alternate juror and failed to object to the replacement of the juror. The Appellate Division affirmed, concluding that Defendant failed to preserve his right to counsel claim. The Court of Appeals affirmed, holding (1) Defendant’s right to counsel claim was not preserved for appellate review; and (2) Defendant’s remaining claims lacked merit. View "People v. Garay" on Justia Law