Justia New York Court of Appeals Opinion Summaries

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

After a jury trial, Defendant was found guilty of two counts of first-degree robbery as an accessory and one count of second-degree murder as an accessory. The Appellate Division affirmed the judgment. Defendant appealed, contending that there was insufficient evidence of a robbery in the course of which the killing occurred. The Court of Appeals affirmed, holding that a rational jury could have inferred beyond a reasonable doubt that Defendant, and the men he aided, stole $40,000 from the victim before attacking the victim, and therefore, the evidence was legally sufficient to support the judgment of conviction.View "People v. Reed" on Justia Law

At issue in this case was N.Y. Crim. Proc. Law 250.10, which requires a defendant to provide notice of intent to offer evidence in connection with the affirmative defense of extreme emotional disturbance (EED). Defendant was convicted of second-degree murder. During trial, Defendant requested that the jury be instructed on EED. The trial court ruled that it would submit an EED charge to the jury on the condition that the People be given the opportunity to present testimony concerning Defendant’s mental state. Consequently, Defendant withdrew his request. Defendant later moved to set aside the verdict, arguing in part that the trial court erred by failing to give the EED charge when the People’s evidence supported that charge. Supreme Court denied the motion, concluding that Defendant’s request for an EED charge served as section 250.10 notice that Defendant intended to proffer psychiatric evidence that supported an EED defense, and thus, the People were entitled to offer testimony to rebut that defense. The Appellate Division affirmed. The Court of Appeals reversed, holding that section 250.10 does not apply where a defendant offers no evidence at trial but requests an EED jury charge based solely upon evidence presented by the People.View "People v. Gonzalez" 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

Defendant was charged with numerous crimes arising from his theft of a minivan and the death of a pedestrian that the minivan struck during a high-speed police chase. After a jury trial, Defendant was found guilty of depraved indifference murder, unlawful fleeing of a police officer in a motor vehicle in the first degree, and grand larceny in the fourth degree. On appeal, Defendant asserted that there was insufficient evidence to support his depraved indifference murder conviction. The Court of Appeals modified the Appellate Division’s order by reducing Defendant’s depraved indifference murder conviction to manslaughter in the second degree, holding that the evidence in this case was legally insufficient to support the conviction because the circumstances did not fit within the narrow category of cases wherein the facts evince a defendant’s utter disregard for human life. View "People v. Maldonado" on Justia Law

After a jury trial, Defendant was convicted of grand larceny and money laundering, both in the second degree, for defrauding the former New York City Mayor, Michael Bloomberg, of $750,000. The Appellate Division affirmed the convictions. On appeal, Defendant argued that the testimony regarding the source of the stolen funds violated the best evidence rule and that, without the testimony, the evidence was insufficient to support the conviction. The Court of Appeals affirmed, holding (1) by the time Defendant raised his objection, other testimony was given that tended to prove ownership, and therefore, the best evidence rule challenge was of no consequence; and (2) nevertheless, the testimony was not so prejudicial as to deny Defendant a fair trial. View "People v. Haggerty" 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

After a jury trial, Defendant was convicted of robbery. During trial, a video recording was admitted into evidence that showed the crime victim being robbed by two men. The victim identified Defendant as one of the robbers and testified to a description he had given the police the night of the crime. Although the victim's description generally fit Defendant, the victim alleged that Defendant was wearing a white shirt the night of the crime, while the man in the video alleged to be Defendant was wearing a blueish-gray shirt. Also during trial, two police officers testified that the victim had given a description on the night of the crime. The officers proceeded to give the accounts of the victim's description. Defendant appealed, arguing that the officers' testimony had improperly bolstered that of the victim. The Court of Appeals affirmed, holding that Defendant's argument failed on the merits because a police officer's testimony to a victim's description, where it does not tend to mislead the jury, may be admissible under the rule set forth in People v. Huertas, which establishes that a crime victim can testify to his own description of his attacker given to the police shortly after the crime. View "People v. Smith" on Justia Law