Justia New York Court of Appeals Opinion Summaries

Defendant was charged with second-degree assault based on a confrontation with Complainant. After a Sandoval hearing, the People received permission to cross-examine Defendant about his recent rape conviction, still pending on direct appeal. Defendant was convicted of third-degree assault. Subsequently, Defendants conviction for rape was reversed, and he was retried and acquitted. The Appellate Division affirmed the assault conviction, holding that the Sandoval issue was unpreserved for appellate review. The Court of Appeals reversed and ordered a new trial, holding (1) the Sandoval issue was properly preserved; (2) the prosecution may not cross-examine about the underlying facts of an unrelated criminal conviction on appeal for the purpose of impeaching his credibility; and (3) accordingly, the trial court's ruling allowing admission of the underlying facts of Defendant's rape conviction was in error, as it violated Defendant's privilege against self incrimination. View "People v. Cantave" on Justia Law

Twelve-year-old Tiffany had a seizure followed by cardiac arrest. Two emergency medical technicians (EMTs) employed by New York City arrived in response to Tiffany's mother's 911 call and began performing CPR on Tiffany until paramedics from a private hospital arrived in an advanced life support ambulance. Tiffany suffered serious brain damages from the ordeal. Tiffany and her mother filed this negligence action against the City and its emergency medical services. Under State law, when a municipality provides ambulance service by emergency medical technicians in response to a 911 call, it performs a governmental function and cannot be held liable unless it owed a special duty to the injured party. Supreme Court granted the City's motion for summary judgment, concluding that the City did not owe Plaintiffs a special duty or that the municipal defendants were the proximate cause of the harm. The Appellate Division reversed, determining that Plaintiffs raised triable issues of fact as to whether the City assumed a special duty to Plaintiffs and whether it proximately caused their injuries. The Court of Appeals affirmed, holding that Plaintiffs adequately established questions of fact on the applicability of the special duty doctrine. View "Applewhite v. Accuhealth, Inc. " on Justia Law

After a jury trial, Defendant was convicted of depraved indifference murder of a child and manslaughter in the first degree. The appellate division affirmed. The Court of Appeals affirmed, holding (1) a rational jury could have found beyond a reasonable doubt that Defendant's state of mind during the crime was one of utter indifference to the value of human life, and therefore, the evidence was sufficient to support Defendant's conviction of depraved indifference murder; (2) the evidence was sufficient to prove that Defendant consciously disregarded the substantial and unjustifiable risk that death or serious injury would result from his actions; (3) the evidence of first-degree manslaughter was sufficient; and (4) Defendant's counsel offered effective assistance. View "People v. Barboni" on Justia Law

After a jury trial, Defendant was convicted of criminal possession in the second degree. Defendant appealed the denial of his motion to suppress the weapon obtained during a search, arguing that the manner in which a police officer conducted the inventory search of Defendant's vehicle was improper, and thus, the entire search was invalid. The Court of Appeals affirmed, holding that the People met their burden of establishing a valid inventory search of Defendant's vehicle, as (1) the search was in accordance with procedure; (2) the search was not made invalid when the officer conducting the search did not follow the written police procedure by giving some of the contents of the vehicle to a third party without itemizing that property; and (3) the fact that the officer searched in the vehicle's seat panels, knowing that contraband is often hidden by criminals in such places, did not invalidate the search because the officer's intention was to search for items to inventory. View "People v. Padilla " on Justia Law

After a jury trial, Defendant was convicted of murder in the second degree and sentenced to twenty-five years to life. Defendant moved to vacate the conviction, arguing that his trial counsel was ineffective for, among several other things, failing to obtain Defendant's psychiatric records. Supreme Court denied the motion. The Appellate Division reversed the denial of the motion to vacate and remanded for a new trial, holding that trial counsel's failure to obtain and review Defendant's psychiatric records deprived Defendant of effective representation. The Court of Appeals affirmed, holding that trial counsel's failure to obtain and review Defendant's psychiatric records and to pursue a strategy informed by both the available evidence and Defendant's concerns seriously compromised Defendant's right to a fair trial. View "People v. Oliveras" on Justia Law

At issue in this case was the constitutionality of the HAIL Act, which regulates medallion taxicabs and livery vehicles. The Act's stated aim is to address certain mobility deficiencies in the City of New York. Plaintiffs, medallion owners and their representatives, challenged the HAIL Act on the ground that the regulation of yellow cab and livery enterprises is a matter of local concern. Specifically, Plaintiffs argued that the Act violates the State Constitution's Municipal Home Rule Clause, the Double Enactment Clause, and the Exclusive Privileges Clause. Supreme Court entered a judgment nullifying the Act and declaring that it violated the Constitution. The Court of Appeals reversed, holding that the HAIL Act does not violate the Municipal Home Rule Clause, the Double Enactment Clause, or the Exclusive Privileges Clause. View "Greater N.Y. Taxi Ass'n v. State" on Justia Law

The Wicks Law requires public entities seeking bids on construction contracts to obtain separate specifications for three subdivisions of the work to be performed. Until 2008 when the law was amended to raise the threshold, the Wicks Law applied to contracts whose cost exceeded $50,000. The new, higher thresholds, unlike the old one, were not uniform throughout the State. Plaintiffs claimed, inter alia, that the amendments violated the Home Rule section of the State Constitution by unjustifiably favoring the eight counties with higher thresholds. Supreme Court dismissed the complaint, holding that Plaintiffs lacked standing to assert the Home Rule cause of action and that, in any event, the challenged amendments did not violate the Home Rule section because they "were enacted in furtherance of and bear a reasonable relationship to a substantial State-wide concern." The Appellate Division affirmed. The Court of Appeals affirmed as modified, holding (1) at least one plaintiff had standing to assert the Home Rule claim, but that claim failed on the merits; and (2) most of Plaintiffs' other claims failed, but four causes of action challenging the apprenticeship requirements as applied to out-of-state contracts should be reinstated. View "Empire State Chapter of Associated Builders & Contractors v. Smith" on Justia Law

Defendant was charged with sex-related crimes. In his summation, defense counsel argued that parts of Complainant's testimony were incredible because a statement Complainant gave to a police officer who responded to her 911 call omitted a number of details that were in Complainant's later testimony and that the People should have called the officer to testify. The trial court directed the jury to disregard counsel's missing witness argument. After summations, defense counsel moved for a mistrial on the basis of this ruling. The court denied the motion, stating that counsel should have asked for a missing witness instruction if he wanted to make a missing witness argument. Defendant was then convicted of criminal sexual act, criminal contempt, and assault. The Appellate Division affirmed, concluding that there was no "good faith basis" for comment by defense counsel on the People's failure to call the officer. The Court of Appeals affirmed, holding that the trial court erred in prohibiting Defendant from making a missing witness argument but that the error was harmless. View "People v. Thomas" on Justia Law

Defendant was arrested for robbery. An attorney from the Legal Aid Society represented Defendant at trial. Prior to opening statements, defense counsel alerted the court to a possible conflict of interest arising from counsel's previous representation of Franklin DeJesus, whom it was rumored to have committed the robbery. After internal discussions with the trial judge, defense counsel proceeded with the case. The jury found Defendant guilty of first-degree robbery. After Defendant's conviction, Legal Aid moved to set aside the verdict based on newly discovered evidence consisting of DeJesus' alleged jailhouse confession to Defendant. Supreme Court denied the motion. The Appellate Division affirmed, determining that Defendant had not been deprived of his right to effective legal assistnce due to Legal Aid's dual representation of Defendant and DeJesus because there was no conflict between their interests. The Court of Appeals affirmed, holding that Defendant did not adequately demonstrate that he received less than meaningful representation, as the record did not establish that the potential conflict actually affected the presentation of the defense or otherwise impaired counsel's performance. View "People v. Sanchez" on Justia Law

Defendant was charged with intentional murder and second-degree weapon possession. Defendant's first trial resulted in a hung jury and mistrial. Defendant was re-tried, and the jury convicted Defendant as charged. After the jury verdict was handed down, the presiding judge, Justice Carter, issued an order recusing himself because of his discovery that he knew the uncle of the victim. In the meantime, Defendant filed a motion seeking an order granting his prior applications for a trial order of dismissal. Justice Palmieri, the judge to whom the case was reassigned, denied Defendant's motion. Defendant appealed, arguing that the evidence was legally insufficient to prove his guilt and that N.Y. Judiciary Law 21 barred any other judge than Justice Carter from deciding his motion. The Appellate Division affirmed. The Court of Appeals affirmed, holding (1) legally sufficient evidence supported Defendant's convictions; and (2) Judiciary Law 21 did not bar Justice Palmieri from ruling on the motion at issue. View "People v. Hampton" on Justia Law