Justia New York Court of Appeals Opinion Summaries

After a jury trial, Defendant was found guilty of murder in the second degree for suffocating her stepdaughter. The Appellate Division found the jury verdict was against the weight of the evidence and modified the County Court’s judgment by reducing the murder conviction to a conviction of second-degree manslaughter. The Court of Appeals affirmed, holding (1) Defendant’s confession to the police following the child’s death was sufficiently corroborated by independent evidence at trial to support Defendant’s conviction; (2) the trial court did not abuse its discretion in admitting certain letters into evidence, as they were sufficiently redacted; and (3) Defendant was not denied effective assistance of trial counsel.View "People v. Santiago" on Justia Law

Upon responding to a burglary report at an apartment building, police officers observed Defendant in the building’s stairwell. When the officers arrested Defendant for trespassing, one of the officers opened Defendant’s shoulder purse, which contained a loaded handgun. Defendant was subsequently indicted for criminal possession of a gun in the second degree and criminal trespass in the second degree. The trial court denied Defendant’s motion to suppress the gun, and, after a jury trial, Defendant was convicted of the counts charged. The Court of Appeals reversed, holding (1) the People bear the burden of demonstrating the presence of exigent circumstances in order to conduct a warrantless search of a closed container incident to arrest; and (2) in this case, the People failed to meet that burden as a matter of law.View "People v. Jimenez" on Justia Law

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

In 2010, Nassau County passed Local Law 18, which shifted the obligation to pay real property tax refunds from the County to its individual taxing districts. Various interested parties filed three actions seeking a declaration that Local Law 18 was null, void and unenforceable because its violated the Municipal Home Rule Law (MHRL) provisions limiting the powers of local government and the State Constitution’s home rule and taxation articles. Supreme Court effectively granted summary judgment to the County in all three actions. The Appellate Division reversed, entering a declaratory judgment that Local Law 18 violated the Constitution and the MHRL. The Court of Appeals affirmed, holding that the County exceeded its statutory and constitutional authority in its attempt to supersede a special State tax law.View "Baldwin Union Free Sch. Dist. v. County of Nassau" 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 1996, Defendant pleaded guilty to third-degree sale of a controlled substance. In 2010, citing Padilla v. Kentucky, Defendant moved to vacate his conviction on the ground that defense counsel was ineffective for failing to advise him of the immigration consequences of his guilty plea. Supreme Court declined to apply Padilla retroactively to Defendant’s claim. The Appellate Division disagreed with Supreme Court, holding that Padilla was to be retroactively applied to pleas after Congress made significant changes in immigration law in 1996. The United States Supreme Court subsequently decided Chaidez v. United States, holding that Padilla does not apply retroactively in federal collateral review. After Chaidez was decided, the Court of Appeals in the instant case reversed the Appellate Division’s order, holding that, pursuant to federal or state retroactivity principles, Padilla does not apply retroactively in state court postconviction proceedings. View "People v. Baret" on Justia Law

In 2012, in an effort to combat obesity among residents of New York City, the New York City Board of Health amended the City Health Code so as to restrict the size of cups and containers used by food service establishments for the provision of sugary drinks. The proposed rule, referred to as the “Portion Cap Rule,” was to go into effect in 2013. Six not-for-profit and labor organizations challenged the Portion Cap Rule. Supreme Court, New York City declared the rule invalid and permanently enjoined its implementation. The Appellate Division affirmed. The Court of Appeals affirmed, holding that, in adopting the Portion Cap Rule, the Board of Health exceeded its regulatory authority and engaged in law-making, thereby infringing upon legislative jurisdiction. View "New York Statewide Coalition of Hispanic Chambers of Commerce v. New York City Dep’t of Health & Mental Hygiene" on Justia Law