Justia New York Court of Appeals Opinion Summaries

Articles Posted in Constitutional Law
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The Court of Appeals affirmed the opinion of the Appellate Division affirming Defendant's conviction of first-degree criminal possession of a forged instrument and seventh-degree criminal possession of a controlled substance, holding that there was legally sufficient evidence of Defendant's "intent to defraud, deceive or injury another" within the meaning of N.Y. Penal Law 170.30. On appeal, the Appellate Division held that the jury could reasonably have inferred from the evidence that Defendant knowingly possessed counterfeit money with fraudulent intent. The Court of Appeals affirmed, holding (1) a rational jury could have found beyond a reasonable doubt that Defendant intended to pass the counterfeit bills in his possession and thereby defraud others; (2) Defendant's objections to the admission of certain testimony were unpreserved; and (3) the arresting officer had reasonable suspicion to justify the original stop of Defendant. View "People v. Britt" on Justia Law

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The Court of Appeals reversed the order of the Appellate Division affirming Defendant's conviction, holding that the trial court abused its discretion as a matter of law and committed reversible error when it refused to allow Defendant to cross-examine two police officers in two specific areas involving officer dishonesty, holding that a law enforcement witness may be subject to cross-examination with respect to a its of dishonesty not proven at trial. In an shooting incident during which no one was injured two police officers identified the shooter as Defendant. At trial, the People's case rested almost entirely on the police officers' identification of Defendant as the shooter. Defendant was convicted of attempted murder in the second degree and related firearm counts. The Appellate Division affirmed. The Court of Appeals reversed, holding (1) a defendant should be permitted to explore specific allegations of wrongdoing relevant to the credibility of a law enforcement witness, and law enforcement witnesses should be treated in the same manner as any other witness for purposes of cross-examination; and (2) Defendant was denied a fair trial inasmuch as the trial court refused to allow him to explore misstatements one of the officers made to a federal prosecutor. View "People v. Rouse" on Justia Law

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The Court of Appeals affirmed the order of the Appellate Division affirming a Supreme Court judgment enjoining a three-day music and camping festival on Landowner's rural property in the Town of Delaware, holding that the challenged provisions of local zoning laws did not unconstitutionally restrict Landowner's First Amendment rights and were not void for vagueness. Landowner planned to sponsor on his sixty-eight-acre property a three-day event during which attendees would camp on the property and view live outdoor music performances. The Town commenced this action seeking an injunction against the event, alleging it was prohibited by the Town's Zoning Law. Supreme Court granted the Town's motion for summary judgment and permanently enjoined Landowner from holding the festival on his property. The Appellate Division affirmed, concluding that that relevant Zoning Law provisions were content-neutral time, place, and manner restrictions compatible with the First Amendment. The Court of Appeals affirmed, holding (1) the zoning provisions at issue satisfied the intermediate scrutiny test for content-neutral time, place and manner restrictions and survived Defendant's overbreadth challenge; and (2) Landowner's facial and as-applied void for vagueness challenges likewise failed. View "Town of Delaware v. Leifer" on Justia Law

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The Court of Appeals affirmed the conclusion of the Appellate Division that the trial court abused its discretion by denying Defendant's N.Y. Crim. Proc. Law 330.30 motion to set aside the verdict against him based on juror misconduct, holding that, under the circumstances of this case, Defendant was entitled to a new trial. Defendant was convicted by a jury of murder and tampering with physical evidence. During the trial, one of the jurors sent and received hundreds of text messages about the case, accessed local media websites that were covering the trial, and lied under oath to the court to hide her misconduct. Defendant moved to set aside the verdict based on juror misconduct. The trial court denied the motion, concluding that the juror's misconduct did not render the trial unfair. The Appellate Division reversed and granted a new trial. The Court of Appeals affirmed, holding that the scope and egregiousness of the deception that occurred in this case required reversal of the conviction and a new trial. View "People v. Neulander" on Justia Law

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The Court of Appeals reversed the order of the Appellate Division affirming Defendant's conviction, holding that the People violated their constitutional obligation to disclose a surveillance video that captured the scene at the time of the shooting, and there was a reasonable probability that the disclosure of the video would have produced a different result at trial. Defendant was convicted of murder for shooting Ruben Alexandre outside an apartment building. The surveillance video of the scene in this case included images of the victim and a key prosecution witness. After receiving the video, Defendant moved to vacate his conviction, arguing that the People's failure to disclose the video violated their obligations under Brady v. Maryland, 373 U.S. 83 (1963). The trial court denied the motion. The Appellate Division affirmed. The Court of Appeals reversed, holding that where the video was withheld from the defense and the jury was told it did not exist, the aggregate effect of the suppression of the evidence undermined confidence in the verdict, and therefore, Defendant was entitled to a new trial. View "People v. Ulett" on Justia Law

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The Court of Appeals affirmed Defendant's conviction of second-degree burglary and petit larceny, holding that defense counsel did not provide ineffective assistance by advancing a jury nullification defense at trial. On appeal, Defendant argued that his trial counsel was ineffective because he exclusively pursued a jury nullification defense to the exclusion of other viable defenses. The Appellate Division affirmed, concluding that defense counsel pursued a reasonable strategy and provided meaningful representation. The Court of Appeals affirmed, holding that the record of counsel's performance demonstrated that Defendant failed to sustain his burden that he was deprived of meaningful representation. View "People v. Mendoza" on Justia Law

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The Court of Appeals affirmed Defendant's conviction of first-degree rape, holding that Defendant did not carry his burden of demonstrating ineffective assistance of counsel and that, even if erroneous, the introduction of DNA evidence was harmless. On appeal, Defendant argued (1) his trial counsel provided ineffective assistance by failing to review or comprehend the significance of surveillance video evidence contradicting his grand jury testimony of a consensual sexual encounter with the victim, and (2) the trial court violated his Sixth Amendment rights by admitting DNA evidence at trial because the analyst who testified at trial did not generate the DNA profile taken from Defendant's buccal swab. The Court of Appeals affirmed, holding (1) defense counsel provided meaningful representation; and (2) because the DNA evidence did not go to the determinative issue of consent, any error in admitting it was harmless. View "People v. Lopez-Mendoza" on Justia Law

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In this personal injury case, the Court of Appeals affirmed the order of the Appellate Division reversing Supreme Court's denial of Defendant's motion for summary judgment, holding that the requisite showing of minimum contacts with New York was lacking. Plaintiffs commenced this personal injury action against several defendants, including the defendant at issue in this appeal, an Ohio firearm merchant who sold a gun to an Ohio resident in Ohio that was subsequently resold on the black market and used in a shooting in New York. Defendant moved for summary judgment, asserting a defense of lack of personal jurisdiction. Supreme Court denied the motion. The Appellate Division reversed and dismissed the complaint as against Defendant. The Court of Appeals affirmed, holding that, in the absence of minimum contacts, New York courts may not exercise personal jurisdiction over Defendant. View "Williams v. Beemiller, Inc." on Justia Law

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The Court of Appeals reversed the judgment of the Appellate Division upholding Defendant's conviction of six counts of first-degree robbery, holding that the trial court created a specter of bias when it negotiated and entered into a cooperation agreement with a codefendant requiring the codefendant to testify against Defendant in exchange for a more favorable sentence. During Defendant's trial, the codefendant testified for the People, admitting to his own involvement in the robbery and identifying Defendant as his accomplice. Defendant moved to preclude the codefendant's testimony, arguing that the cooperation agreement between between the trial court and the codefendant indicated that the court had abdicated its responsibility to act in a neutral and detached manner. The trial court denied Defendant's motion, and Defendant was convicted. The Appellate Division upheld the judgment of conviction. The Court of Appeals reversed, holding that the trial court abandoned the role of a neutral arbiter and assumed the function of an interested party, thus denying Defendant his due process right to a fair trial in a fair tribunal. View "People v. Towns" on Justia Law

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The Court of Appeals affirmed the decision of the Appellate Division affirming Defendant's conviction of attempted assault in the first degree, holding that a portion of a testifying witness's prior grand jury testimony was properly admitted as a past recollection recorded to supplement his trial testimony. The Appellate Division held that the trial court properly exercised its discretion in admitting the grand jury testimony as a past recollection recorded because the People laid a proper foundation for the admission of the testimony and that there was no violation of the Confrontation Clause because the witness testified at trial and was subject to cross-examination. The Court of Appeals affirmed, holding that there was a proper foundation for receipt of the evidence and that Defendant's Sixth Amendment right to confrontation was not violated. View "People v. Tapia" on Justia Law