Justia New York Court of Appeals Opinion Summaries

In 1968, Respondent pleaded guilty to rape and robbery. A federal court later vacated Respondent’s convictions. In 1978, Respondent was convicted of rape in the first degree. After Respondent was released on parole, he pleaded guilty in 1996 to rape in the first degree. Prior to Respondent’s release from custody, the State filed a petition under N.Y. Mental Hyg. Law 10 seeking a determination that Respondent was a detained sex offender requiring civil management. Respondent moved to preclude expert testimony relating to both the 1968 charges and an uncharged rape Respondent allegedly committed in 1978. Supreme Court denied the motion. After a trial, the jury returned a verdict finding that Respondent suffered from a mental abnormality qualifying him for civil management under article 10. Supreme Court subsequently ordered Respondent committed to a secure treatment facility. The Court of Appeals affirmed, holding (1) basis hearsay related to Respondent’s 1968 indictments for rape and robbery met minimum due process requirements and was properly admitted at trial; and (2) basis hearsay about Respondent’s uncharged rape was unreliable and should have been excluded, but its admission was harmless error. View "State v. John S." on Justia Law

A grand jury charged Defendants, the president and CEO of a leading materials testing company and the company’s vice-president, with engaging in a pattern of criminal activity while intentionally conducting and participating in the affairs of a criminal enterprise. The indictment alleged that Defendants committed or allowed certain of the company’s employees to engage in illegal acts involving the falsification of test results, improper inspections of construction projects, and double-billing of clients. After a jury trial, both defendants were convicted of enterprise corruption and several non-enterprise corruption offenses. The Appellate Division modified by vacating the enterprise corruption convictions on the basis that the convictions lacked sufficient proof and were against the weight of the evidence. Both parties appealed. The Court of Appeals affirmed as modified, holding that the Appellate Division did not apply the proper legal standards when it reviewed the sufficiency of the evidence supporting Defendants’ convictions for enterprise corruption and that the People’s evidence was legally sufficient to support the enterprise corruption convictions. Remanded. View "People v. Kancharla" on Justia Law

Defendant struck and killed a pedestrian while driving an automobile and was subsequently transported to police headquarters. While Defendant’s attorney was pursuing telephone contact with law enforcement personnel, the police obtained Defendant’s consent to administer a breathalyzer test. After Defendant took the test, she was indicted for second-degree manslaughter, second-degree vehicular manslaughter, and two counts of driving while intoxicated. Defendant filed a motion to suppress the results of the breathalyzer test on the grounds that it had been administered in violation of her right to counsel. Supreme Court granted the motion and suppressed the chemical tests. The Appellate Division affirmed. The Court of Appeals affirmed, holding that the police violated Defendant’s constitutional right to counsel because Defendant was not alerted to the lawyer’s communication before the breath test occurred and because the People did not demonstrate that a notification of this nature would have been unreasonable under the circumstances. View "People v. Washington" on Justia Law

After a jury trial, Defendant was charged with burglary in the second degree. The People sought permission to admit a witness’s grand jury testimony into evidence, alleging that Defendant had forfeited his right to preclude the admission of the testimony because he procured the witness’s unavailability by coercing her into invoking her Fifth Amendment privilege. The trial court granted the People’s motion and submitted the witness’s grand jury testimony for the jury’s consideration. The jury returned a verdict convicting Defendant as charged. The Court of Appeals affirmed, holding that the trial court properly ruled that Defendant forfeited his right to preclude the admission of the witness’s grand jury testimony by his wrongdoing because there was clear and convincing circumstantial evidence that Defendant was a cause of the witness’s refusal to testify. View "People v. Smart" on Justia Law

After a jury trial, Defendant was convicted of rape. During the prosecution, Defendant sought disclosure of the complainant’s mental health records. After an in camera review of the records, which contained thousands of documents, the trial court selected twenty-eight pages for disclosure. Defendant appealed, arguing that the trial court abused its discretion in withholding the undisclosed documents. The Appellate Division affirmed. The Court of Appeals affirmed, holding (1) the trial court could reasonably think there was no more than a remote possibility that disclosure of the records it withheld would lead to Defendant’s acquittal; and (2) the trial court was within its discretion in finding the records’ relevance to be outweighed by the complainant’s legitimate interest in confidentiality. View "People v. McCray" on Justia Law

Defendant and his codefendants were charged via a sixty-one count indictment with several crimes arising from a sophisticated scheme to steal property through the use of forged credit cards. The case proceeded to trial on twenty-six of the counts. The jury found Defendant guilty on twenty of the twenty-six counts. Defendant appealed, arguing (1) the trial court ran afoul of N.Y. Crim. Proc. Law 310.20(2) when it submitted to the jury a verdict sheet containing the locations of the designated offenses; and (2) law enforcement’s warrantless installation of a GPS tracking device on Defendant’s vehicle violated this Court’s holding in People v. Weaver and the holding of the U.S. Supreme Court in United States v. Jones. The Court of Appeals affirmed, holding (1) the trial court appropriately included the annotations on the verdict sheet so that the jury could distinguish the submitted counts; and (2) Defendant’s constitutional rights were violated by the warrantless installation of the GPS tracking device on his vehicle, but the violation was harmless beyond a reasonable doubt. View "People v. Lewis" on Justia Law

Defendant was charged with second-degree murder and criminal possession of a weapon in the fourth-degree. Supreme Court submitted to the jury the indicted charge of second-degree murder and first-degree manslaughter as a lesser included offense. The jury acquitted Defendant of murder and found him guilty of first-degree manslaughter. Defendant appealed, arguing that the trial court erred by refusing to submit a second-degree manslaughter charge to the jury because a reasonable view of the evidence supported the conclusion that he killed the victim recklessly. The Appellate Division affirmed. The Court of Appeals affirmed, holding that the record did not reasonably support the conclusion that Defendant acted with mere recklessness. View "People v. Rivera" on Justia Law

Defendant was charged with first and second degree robbery and other crimes. The first degree robbery charge was based on the alleged display of a firearm. The jury at Defendant's first trial acquitted Defendant of first degree robbery and convicted him of second degree robbery. The Appellate Division reversed and ordered a new trial on the second degree robbery charge. At Defendant's second trial, Defendant filed a motion to preclude the People from introducing evidence that a gun was used in the robbery. The trial court denied the motion and Defendant was again convicted of second degree robbery. The Appellate Division again reversed, holding that the People were collaterally estopped by the earlier verdict from presenting evidence of the gun. The Court of Appeals affirmed, holding that, pursuant to People v. Acevedo, the issue of the display of the gun, which was an issue of evidentiary fact resolved in Defendant's favor by a jury, the People were barred at Defendant's second trial from presenting evidence that contradicted the first jury's finding. View "People v. O'Toole" on Justia Law

Defendant was charged with arson in the third degree, insurance fraud in the second degree, and reckless endangerment in the first degree. Defendant's first trial ended in a hung jury. At his second trial, the jury found Defendant guilty of insurance fraud in the second degree but acquitted him of the other charges. Defendant appealed, arguing that because the jury acquitted him of arson, the evidence was insufficient to support his conviction for insurance fraud. The Appellate Division affirmed. The Court of Appeals affirmed, holding that the factual inconsistency in the jury verdict acquitting Appellant of one count but convicting him of another did not render the evidence legally insufficient to support the conviction. View "People v. Abraham" on Justia Law

After a jury trial, Defendants were convicted of first-degree robbery. Defendants appealed, arguing, among other things, that their counsel provided ineffective assistance by failing to assert as an affirmative defense that one of two weapons displayed during the gunpoint robbery was not "a loaded weapon from which a shot, readily capable of producing death or serious physical injury, could be discharged" pursuant to N.Y. Penal Law 160.15. The Appellate Division affirmed. The Court of Appeals affirmed, holding (1) defense counsel were not ineffective for neglecting to challenge the sufficiency of the evidence or for failing to put the affirmative defense before the jury; and (2) the record supported the lower courts' determination that the robbery victim's showup identification of Defendants was proper. View "People v. Howard" on Justia Law