Justia New York Court of Appeals Opinion Summaries

After a jury trial, Defendant was convicted of manslaughter in the first degree. On appeal, Defendant argued that the trial court erred by not submitting to the jury the question of whether the People’s key witness was an accomplice and, if so, whether his testimony was sufficiently corroborated. The Appellate Division affirmed the conviction, concluding that the witness could not reasonably be considered to have participated in the crime and that there was overwhelming evidence corroborating his testimony. The Court of Appeals reversed, holding that the evidence created a factual issue as to whether the witness was an accomplice, and the trial court’s failure to charge the jury with an “accomplice-in-face” instruction was not harmless.View "People v. Sage" on Justia Law

In 2001, Defendant was found guilty of robbery and other crimes and sentenced to terms of imprisonment. Supreme Court later ordered that Defendant be resentenced, determining that Defendant’s sentence was illegal because it did not include a mandatory term of post-release supervision (PRS). After Defendant was conditionally released, Supreme Court resentenced Defendant by imposing a term of PRS. In 2009, the maximum term of Defendant’s prison sentence passed. In 2010, Defendant filed a motion to set aside his second sentence, arguing that the imposition of PRS constituted double jeopardy because he was out of prison on conditional release when it was imposed. Supreme Court granted the motion and resentenced Defendant, reimposing the terms of his completed initial sentence. The Appellate Division dismissed the People’s appeal, concluding that imposing PRS in this case would constitute double jeopardy. The Court of Appeals reversed, holding (1) Defendant had not acquired a legitimate expectation of finality in his sentence because the direct appeal of the sentence Defendant served was not over; and (2) therefore, the prohibition against double jeopardy was not implicated in this case.View "People v. Cintron" on Justia Law

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

Defendant was charged with third-degree sexual abuse, forcible touching, and public lewdness for rubbing his exposed penis against another man’s buttocks without the victim’s consent. Defendant pleaded guilty to forcible touching in full satisfaction of the information. Defendant appealed, contending that the information was jurisdictionally defective because it stated that Defendant simply “rubbed” his groin and exposed his penis against the victim’s intimate parts, which conduct did not fulfill the “forcible” component of the crime. The Appellate Term affirmed. The Court of Appeals affirmed, holding that any bodily contact involving the application of some level of pressure to the victim’s sexual or intimate parts qualifies as a forcible touch within the meaning of N.Y. Penal Law 130.52. View "People v. Guaman" on Justia Law

Defendant was charged with attempted murder and other crimes. During voir dire, a number of bench conferences were at held at which prospective jurors’ qualifications were discussed. Defendant did not attend, or ask to attend, any of these conferences. Defendant was convicted, and the Appellate Division affirmed. The Court of Appeals affirmed, holding that Defendant validly his right under People v. Antommarchi to be present during bench conferences at which prospective jurors are questioned on voir dire. Specifically, Defendant waived his Antommarchi right, both implicitly and explicitly, when (1) after hearing the trial judge say Defendant was “welcome to attend” the bench conferences, Defendant chose not do to so, and (2) Defendant's lawyer stated that Defendant waived his Antommarchi right.View "People v. Flinn" on Justia Law

Defendant was arrested on suspicion of murder. At a second grand jury proceeding, Defendant vigorously urged the grand jury to have the People call a particular witness, Jane Doe, to testify. The grand jurors rejected Defendant’s request for the witness’s testimony and, thereafter, indicted Defendant on various charges, including second-degree murder. Defendant was subsequently tried and convicted of second-degree murder by a jury. Defendant appealed, arguing that the prosecutors’ commentary to the grand jury on his request to call Jane Doe compelled the grand jury to surrender all independent discretion in the matter and thus impaired the integrity of the proceedings. The Court of Appeals affirmed, holding that, although the prosecutors should have shown greater sensitivity to Defendant’s request and the grand jurors’ concerns, in light of the totality of the circumstances that arose in the second grand jury proceeding, the prosecutors’ actions did not impair the integrity of that proceeding or warrant dismissal of Defendant’s conviction. View "People v. Thompson" 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

After a jury trial, Defendants were convicted of attempted robbery. On appeal, Defendants argued that the trial judge abused his discretion when he declined to deliver an adverse inference charge regarding the loss of a handwritten complaint report prepared by a police officer who responded to a 911 call reporting the robbery that led to Defendant’s conviction. The Appellate Division affirmed. The Court of Appeals also affirmed, holding (1) Defendants failed to meet their burden of establishing that they were prejudiced by the loss of the report, and therefore, no sanction was warranted; and (2) Defendants’ respective robbery convictions were supported by legally sufficient evidence.View "People v. Martinez" on Justia Law

Defendant was tried on two counts of burglary. At his jury trial, Defendant asked to proceed pro se. Ultimately, the trial court granted Defendant’s request to represent himself. Defendant was convicted of the two counts of burglary. On appeal, Defendant argued that his constitutional right to counsel was violated when the trial court failed sua sponte to inquire into his mental capacity to represent himself prior to granting his application to proceed pro se. The Court of Appeals affirmed, holding (1) the trial court did not abuse its discretion in failing to undertake a particularized assessment of Defendant’s mental capacity when resolving his request to proceed pro se; (2) there was no basis to disturb the conviction on Faretta grounds; and (3) Defendant’s argument that the trial court should have ordered a N.Y. Crim. Proc. Law 730.30 examination to assess whether Defendant possessed the baseline mental competency to stand trial was without merit.View "People v. Stone" on Justia Law