Justia New York Court of Appeals Opinion Summaries

The Court of Appeals affirmed the judgments of the trial court in both of these cases, holding that both courts erred by reversing, after summations, their prior rulings on Defendants' requests to charge the jury, but these errors did not mandate reversal.The appellate courts affirmed Defendants' convictions on both cases at issue on appeal, ruling that both lower courts erred by failing to charge the jury in accordance with the courts' pre-summation rulings on Defendants' charging requests but that the error was harmless. The Court of Appeals affirmed, holding (1) a trial court's error in reversing a prior charging decision after summations have been completed is subject to harmless error analysis; and (2) where the evidence of guilt in both cases was overwhelming, the error in each case was harmless. View "People v. Mairena" on Justia Law

In these three consolidated appeals the Court of Appeals addressed the issue of imprecise language in Defendants' written waivers of the right to appeal that mischaracterized the scope of the appellate rights waived as a condition of the plea bargains, adhering to well-established precedent in affirming in one case and reversing in other two cases.At issue was whether, under the circumstance of each of the three cases, the mischaracterizations impacted the knowing and voluntary nature of the three appeal waivers before the Court. The Court of Appeals (1) affirmed in one case, holding that the appeal waiver was knowingly and voluntarily entered; and (2) reversed in the other two cases, holding that the appeal waivers were involuntarily made and thus not enforceable. View "People v. Thomas" on Justia Law

The Court of Appeals affirmed the order of the Appellate Division rejecting Defendant's challenges to his conviction of two counts of manslaughter in the second degree, holding that Defendant's conduct may be prosecuted as a homicide offense and that the conviction was supported by legally sufficient evidence.Two of Defendant's patients died of overdoses caused by a combination of oxycodone and alprazolam shortly after filling prescriptions for the drugs issued by Defendant. Defendant was convicted of two counts of manslaughter in the second degree and related offenses. On appeal, Defendant argued, among other things, that he could not be convicted of any homicide offense for providing controlled substances that result in an overdose death. The Court of Appeals affirmed, holding (1) there is no basis to conclude that the legislature intended to exclude from the ambit of homicide statutes the prosecution of a defendant who engages, with the requisite mens rea, in conduct through the provision of dangerous drugs that directly causes a person's death; and (2) sufficient evidence supported the conviction. View "People v. Li" on Justia Law

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

The Court of Appeals reversed the judgment of the Appellate Division granting a writ of habeas corpus, holding that Supreme Court did not abuse its discretion by disapproving an insurance company bail bond package assembled by a bail bond company in conjunction with Defendant's family and friends.Supreme Court disapproved the bond at issue when exercising its review under N.Y. Crim. Proc. Law 520.30(1), concluding that the pledged collateral was "virtually nonexistent" and provided Defendant "with no incentive to return to court." Relator commenced this N.Y. C.P.L.R. 70 habeas corpus proceeding on Defendant's behalf. The Appellate Division sustained the writ and directed that Defendant be released upon his posting of an insurance company bail bond in the aggregate sum of $500,000, ruling that Supreme Court erred in disapproving the bail. The Court of Appeals reversed, holding (1) section 520.30(1) permits a court to determine whether the collateral securing the insurance company bail bond is so deficient that it fails to ensure the defendant's return to court in contravention of public policy; and (2) Supreme Court correctly interpreted the statute and did not abuse its discretion when it disapproved the bail package on public policy grounds. View "People ex rel. Prieston v. Nassau County Sheriff's Department" on Justia Law

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

The Court of Appeals affirmed the order of the Appellate Division reversing the judgment of County County convicting Defendant, a level three sex offender, of failing to register his Facebook account, concluding that Facebook is not an "internet identifier" and that the existence of a Facebook account need not be disclosed to the Division of Criminal Justice Services (DCJS) pursuant to N.Y. Corp. Law 168-f(4).Pursuant to section 168-a(18), "internet identifiers" are defined as "electronic mail addresses and designations used for purposes of chat, instant messaging, social networking or other similar internet communication." The People argued that Defendant was required to register his Facebook account as an "internet identifier" pursuant to section 168-f(4). The Appellate Division concluded that a Facebook account is not an "internet identifier" that Defendant must disclose to DCJS. The Court of Appeals affirmed, holding that that Facebook is not an "internet identifier" and that the existence of a Facebook account - as opposed to the internet identifiers a sex offender may use to access Facebook or interact with other users on Facebook - need not be disclosed to DCJS pursuant to section 168-f(4). View "People v. Ellis" on Justia Law

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

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

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