Justia New York Court of Appeals Opinion Summaries

After a jury trial, Defendant was convicted of depraved indifference murder for murdering his infant son. The Appellate Division affirmed Defendant’s conviction. The Supreme Court reversed and directed a new trial, holding (1) the evidence was sufficient to demonstrate that Defendant, with depraved indifference to human life, recklessly engaged in conduct that created a grave risk of serious physical injury to the four-month-old, thereby causing the child’s death; but (2) Defendant’s previously denied motion to suppress inculpating statements he made to interrogators was in error because the statements were not demonstrably voluntary, and Defendant’s confession should not have been placed before the jury.View "People v. Thomas" on Justia Law

After a nonjury trial, Defendant was convicted of unlawful surveillance in the second degree for standing outside the front door of his neighbor’s townhouse and filming the complainant while she was naked in her second floor bathroom. Defendant appealed, arguing that insufficient evidence supported his conviction. The Appellate Division affirmed, concluding that the evidence established that Defendant had surreptitiously recorded the complainant for his own amusement at a time and place where she had a reasonable expectation of privacy. The Court of Appeals affirmed, holding that each element of the offense of unlawful surveillance in the second degree was established beyond a reasonable doubt.View "People v. Schreier" on Justia Law

In 2000, Defendant pleaded guilty to first-degree manslaughter and was sentenced to twenty-three years incarceration. After Defendant’s incarceration, the Department of Correctional Services added a five-year PRS term to her certificate of commitment. In 2009, Defendant filed a pro se motion claiming that her plea was defective and her sentence illegal because she was not informed before she was incarcerated that she would be required to serve an additional term of PRS. Defendant was resentenced to the original sentence of twenty-three years without a term of PRS. Defendant appealed the resentence. Defendant’s counsel filed a motion under People v. Crawford asking to be relieved as counsel because there were no non-frivolous issues to be raised on Defendant’s behalf. Defendant subsequently filed a pro se supplemental brief arguing, inter alia, that the sentence was illegal. The appellate division granted counsel’s motion and affirmed the resentence without addressing Defendant’s pro se contentions. The Court of Appeals reversed, holding that the appellate division erred in granting the Crawford motion, and therefore, remittal for a de novo appeal was warranted.View "People v. Beaty" on Justia Law

Defendant, a high school student, anonymously posted sexual information and photographs of fellow classmates and other adolescents on Facebook, a social networking website. Defendant was charged with and pleaded guilty to cyberbullying under a local law enacted by the Albany County Legislature. Defendant appealed, arguing that the cyberbullying law violated the Free Speech Clause of the First Amendment. The Court of Appeals reversed, holding that Albany County’s cyberbullying law was overbroad and facially invalid under the Free Speech Clause because the text of the law criminalized a variety of constitutionally-protected modes of expression - a great deal more than acts of cyberbullying. View "People v. Marquan M." on Justia Law

After a jury trial, Defendant was convicted of two counts of murder in the second degree. The Appellate Division affirmed on direct appeal. Approximately a decade later, Defendant moved to vacate his judgment of conviction, asserting that the People committed a Brady violation by failing to disclose to him that a federal civil action had been brought against one of their police witnesses, a homicide detective who interrogated Defendant, based on the detective’s alleged police misconduct in an unrelated case. The Appellate Division remitted the matter for a hearing, determining that the civil allegations against the detective constituted impeachment evidence and that the People’s failure to disclose them may have deprived Defendant of a fair trial. The Court of Appeals reversed, holding that, although the civil allegations were favorable to Defendant, he failed to prove that the People suppressed the information or that he was prejudiced by the undisclosed information. View "People v. Garrett" on Justia Law

In the first case involved in this appeal, Defendant pleaded guilty to criminal possession of marihuana. Defendant appealed, asserting that his plea was invalid because the record did not affirmatively demonstrate the waiver of his Boykin rights. The Appellate Term affirmed. In the second case, Defendant pleaded guilty to criminal sale of marihuana. Defendant appealed, arguing, as in the first case, that the waiver of his Boykin rights was nonexistent. The Appellate Term affirmed. The Court of Appeals reversed in both cases, holding that because the records in both cases were silent as to Defendant's waiver of his Boykin rights, the pleas must be vacated.View "People v. Tyrell" on Justia Law

Defendant, the son of a Dead Sea Scrolls scholar, launched an internet campaign to attack the integrity and harm the reputation of other Dead Sea Scrolls academics and scholars. To accomplish his goal of discrediting and harming these individuals, Defendant used pseudonyms and impersonated real academics and scholars in communicating with academics, museum administrators, and reporters. A jury convicted Defendant on thirty counts, including several counts of identity theft, criminal impersonation, forgery, and aggravated harassment. The Court of Appeals affirmed the convictions for nine counts of criminal impersonation in the second degree and all the convictions for forgery and vacated the remainder of the convictions, holding (1) the mere creation of email accounts in others’ names, which accounts are not used, does not constitute criminal conduct; (2) the aggravated harassment statute is unconstitutionally vague and overbroad; (3) the People did not sustain their burden of proof that Defendant was guilty of unauthorized use of university computers; and (4) there was insufficient evidence to support Defendant’s convictions of identity theft in the second degree. View "People v. Golb" on Justia Law

In 1968, Respondent pleaded guilty to rape and robbery. A federal court later vacated Respondent’s convictions. In 1978, Respondent was convicted of rape in the first degree. After Respondent was released on parole, he pleaded guilty in 1996 to rape in the first degree. Prior to Respondent’s release from custody, the State filed a petition under N.Y. Mental Hyg. Law 10 seeking a determination that Respondent was a detained sex offender requiring civil management. Respondent moved to preclude expert testimony relating to both the 1968 charges and an uncharged rape Respondent allegedly committed in 1978. Supreme Court denied the motion. After a trial, the jury returned a verdict finding that Respondent suffered from a mental abnormality qualifying him for civil management under article 10. Supreme Court subsequently ordered Respondent committed to a secure treatment facility. The Court of Appeals affirmed, holding (1) basis hearsay related to Respondent’s 1968 indictments for rape and robbery met minimum due process requirements and was properly admitted at trial; and (2) basis hearsay about Respondent’s uncharged rape was unreliable and should have been excluded, but its admission was harmless error. View "State v. John S." on Justia Law

Petitioners and other members of the East Meadow Teachers Association displayed picketing signs from their cars parked where parents were dropping their children off at Woodland Middle School. The Board of Education of the East Meadow Union Free School District (District) charged Petitioners with misconduct related to the demonstration, claiming that Petitioners created a safety risk by parking their cars so that students had to be dropped off in the middle of the street instead of at curbside. Petitioners were found guilty of misconduct. Petitioners appealed, arguing that the disciplinary proceedings against them violated their right to free speech. Supreme Court denied the petitions. The Appellate Division reversed after applying the two-part balancing test set forth in Pickering v. Board of Education of Township High School. The Court of Appeals reversed, holding (1) the picketing demonstration was a form of speech protected by the First Amendment; but (2) Petitioners’ interests in engaging in constitutionally protected speech in the particular manner they employed on the day in question were outweighed by the District’s interests in safeguarding students and maintaining effective operations at the middle school. View "Santer v. Bd. of Educ. of E. Meadow Union Free Sch. Dist." on Justia Law

Defendant struck and killed a pedestrian while driving an automobile and was subsequently transported to police headquarters. While Defendant’s attorney was pursuing telephone contact with law enforcement personnel, the police obtained Defendant’s consent to administer a breathalyzer test. After Defendant took the test, she was indicted for second-degree manslaughter, second-degree vehicular manslaughter, and two counts of driving while intoxicated. Defendant filed a motion to suppress the results of the breathalyzer test on the grounds that it had been administered in violation of her right to counsel. Supreme Court granted the motion and suppressed the chemical tests. The Appellate Division affirmed. The Court of Appeals affirmed, holding that the police violated Defendant’s constitutional right to counsel because Defendant was not alerted to the lawyer’s communication before the breath test occurred and because the People did not demonstrate that a notification of this nature would have been unreasonable under the circumstances. View "People v. Washington" on Justia Law