Justia New York Court of Appeals Opinion Summaries

Defendant was arrested after law enforcement officers noticed him walking on a roadway with wet blood stains on his clothes, hands, and shoes. Because the officers believed a person may have been injured, they continued to question Defendant despite his request for legal assistance. Eventually, officers discovered Defendant's business partner lying dead in his driveway. Defendant was indicted for second-degree murder and moved to suppress statements he made to the police and an acquaintance, as well as the physical evidence, claiming he had been arrested without probable cause and interrogated in violation of his right to counsel and without having received Miranda warnings. The county court ruled that the detention and questioning of Defendant were justified under the emergency doctrine. After a jury trial, Defendant was convicted as charged. The Court of Appeals affirmed, holding (1) the record supported the determination that the emergency doctrine justified the police questioning; and (2) the courts below did not err in finding that Defendant's assertions were voluntary and admissible at trial. View "People v. Doll" on Justia Law

After a jury trial, Defendant was convicted of possession of a weapon not in his home or place of business and sentenced to a term of imprisonment. The Appellate Division affirmed. Appellant appealed, arguing that the trial court's admission of a 911 telephone call reporting that a person matching Defendant's description committed an uncharged gunpoint robbery and police testimony describing the radio run they received about the call deprived him of a fair trial. The Court of Appeals affirmed, holding that, under the circumstances of this case, the trial court did not abuse its discretion by permitting the 911 evidence to be admitted, along with several limiting instructions, as background information to explain the aggressive police action toward Defendant. View "People v. Morris" on Justia Law

Appellant owned a part-time residence in New York but intended to make Louisiana his primary residence. Appellant applied for a New York State pistol/revolver license pursuant to N.Y. Penal Law 400.00 and inquired whether he would still be eligible for a handgun license. The county court judge denied Appellant's application for a handgun license, concluding that the term "residence" was equivalent to "domicile," and therefore, because Appellant was not domiciled in New York, he was ineligible for the license. Appellant commenced this action pursuant to 42 U.S.C. 1983, alleging that the judge had violated his right to keep and bear arms and his right to equal protection by denying his license application on the ground of his domicile. The district court granted the judge summary judgment. Upon Appellant's appeal, the Second Circuit Court of Appeals certified a question to the N.Y. Court of Appeals. The Court answered by holding that an applicant who owns a part-time residence in New York but makes his permanent domicile elsewhere is eligible for a New York handgun license in the city or county where his part-time residence is located. View "Osterweil v. Bartlett" on Justia Law

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

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

Petitioner was a State employee. Suspecting that Petitioner was submitting false time reports, the State attached a global positioning system (GPS) device to Petitioner's car. After a report by the Inspector General based on evidence obtained from the GPS device, the Commissioner of Labor terminated Petitioner's employment. The appellate division confirmed the Commissioner's determination and dismissed the petition. The Court of Appeals affirmed, holding (1) pursuant to People v. Weaver and United States v. Jones, the State's action was a search within the meaning of the State and Federal Constitutions; (2) the search in this case did not require a warrant; but (3) the State failed to demonstrate that the search was reasonable. Remanded. View "Cunningham v. State Dep't of Labor" on Justia Law

In these two unrelated cases, Defendants were resentenced because the sentencing court failed to impose mandatory postrelease supervision (PRS) as part of the original sentence. Defendants appealed, concluding that the imposition of PRS to their determinate sentences at resentencing violated Double Jeopardy Clause. The Appellate Division affirmed the resentences, concluding that Defendants did not have a legitimate expectation of finality in their respective determinate sentences because they had not completed their aggregated sentences prior to resentencing. The Court of Appeals affirmed, holding that Defendants' respective resentences did not violate the Double Jeopardy Clause because Defendants did not have a legitimate expectation of finality until they had completed their aggregated sentences under N.Y. Penal Law 70.30. View "People v. Brinson" on Justia Law

Defendant was convicted of burglary in the first degree and robbery in the second degree. Defendant appealed, arguing that his arrest was illegal, and therefore, his subsequent lineup identification as the perpetrator of the crime was the fruit of an illegal arrest. The Appellate Division affirmed, holding (1) the officer who arrested Defendant lacked probable cause to stop and arrest Defendant; but (2) an "intervening event" attenuated the causal connection between the illegal arrest and the lineup identification. The Court of Appeals affirmed, holding (1) the initial arrest of Defendant was without probable cause and therefore illegal; but (2) at the time of the lineup identification, any taint of the illegal arrest had been attenuated. View "People v. Jones" on Justia Law