Justia New York Court of Appeals Opinion Summaries

After an altercation with police officers at a train station, Defendant and his brother fled the scene, leaving a bag on the platform. Based on the bag's contents, Defendant was arrested and charged with second-degree criminal possession of a weapon and resisting arrest. The police officers later identified Defendant in a photo array. Defendant moved to suppress the contents of the bag and the identifications. Supreme Court initially granted the motion but subsequently reopened the suppression hearing and denied the motion to suppress. After a jury trial, Defendant was convicted as charged. The Appellate Division reversed, concluding that Supreme Court (1) erred when it reopened the suppression hearing because the People had been given the opportunity to present their evidence the first time around, and (2) should have granted reargument rather than reopening and, upon reargument, adhered to its initial suppression order because the police lacked reasonable suspicion to stop Defendant. The Court of Appeals affirmed, holding that the principles underlying People v. Havelka preclude a trial judge from reopening a suppression hearing to give the People an opportunity to shore up their evidentiary or legal position absent a showing they were deprived of a full and fair opportunity to be heard. View "People v. Kevin W." on Justia Law

Defendants in these three consolidated appeals were convicted of depraved indifference murder for driving in an outrageously reckless manner while intoxicated by alcohol or drugs and causing the death of at least one other person. Defendants challenged their convictions, contending that the evidence was not legally sufficient to support their convictions. Specifically, Defendants asserted that there was insufficient proof they had the requisite mental state of depraved indifference. The Court of Appeals affirmed the convictions, holding that there was sufficient evidence in each case that Defendants were aware of and appreciated the risks caused by their behavior. View "People v. Heidgen" on Justia Law

In 2011, Petitioner was convicted several crimes. In 2012, Petitioner was convicted of additional crimes. In all, Petitioner was sentenced to five definite one-year terms of imprisonment, four of which were imposed to run consecutively. Respondents calculated Petitioner's consecutive definite sentences by awarding Petitioner jail time credit for time served prior to the commencement of his 2011 sentences as well as good time credit. Respondents then applied these credits against Petitioner's court-imposed aggregate term of imprisonment, reducing it to 868 days. Because this term was longer than two years imprisonment, Respondents adjusted Petitioner's discharge date to exactly two years from the date his sentences commenced. Petitioner filed a petition seeking to compel Respondents to recalculate his sentence by applying his jail time and good time credits against the two-year term imposed under N.Y. Penal Law 70.30(2)(b). The Appellate Division ordered Petitioner's immediate release from county jail. The Court of Appeals affirmed, holding that, when Penal Law 70.30(2)(b) limits consecutive definite sentences to an aggregate term of two years imprisonment, jail time credit and good time credit should be deducted from that two-year aggregate term rather than the aggregate term imposed by the sentencing court. View "People ex rel. Ryan v. Cheverko" on Justia Law

After a jury trial, Appellant was convicted of sexual abuse in the first degree and endangering the welfare of a child. Prior to Appellant's release from prison, the Department of Correctional Services transferred Appellant to Kirby Psychiatric Center. During his confinement at Kirby, the State filed a N.Y. Mental Hyg. Law 10 civil management petition against Appellant. A jury found that Appellant suffered from a mental abnormality, and the court assigned him to the Office of Mental Health for confinement in a secure facility. Appellant appealed, arguing, inter alia, that Supreme Court erred when it allowed experts to testify to unreliable hearsay when the hearsay served as the underlying basis for the experts' opinion. The Appellate Division affirmed. The Court of Appeals reversed and ordered a new trial, holding (1) the trial court improperly permitted the State's experts to introduce certain unreliable hearsay as well as some hearsay with a patina of reliability that nevertheless was more prejudicial than probative as a matter of law; and (2) these errors denied Appellant due process. View "State v. Floyd Y." on Justia Law

At issue in these consolidated criminal appeals was whether, prior to permitting a defendant to plead guilty to a felony, a trial court must inform the defendant, if the defendant is not U.S. citizen, that he or she may be deported as a result of the plea. The Court of Appeals held that due process compels a trial court to apprise a defendant that, if the defendant is not a U.S. citizen, he or she may be deported as a consequence of a guilty plea to a felony. In so holding, the Court (1) overruled the portion of its decision in People v. Ford which held that a court's failure to advise a defendant of potential deportation does not affect the validity of the defendant's plea; and (2) held that the trial court's failure to notify a pleading non-citizen defendant of the possibility of deportation does not entitle the defendant to automatic withdrawal or vacatur of the plea, but rather, in order to overturn his or her conviction, the defendant must establish the existence of a reasonable probability that, had the court warned the defendant of potential deportation, the defendant would have rejected the plea and opted to go to trial. View "People v. Peque" on Justia Law

Defendant was charged with one count of criminal possession of a weapon in the second degree for possessing a loaded firearm. The count was based on evidence that a loaded gun was found in Defendant's home. With the indictment, the People filed a special information alleging that Defendant had previously been convicted of criminal possession of a controlled substance in the first degree. Supreme Court reduced the charge to third degree possession. The Appellate Division reversed and reinstated the second degree charge. At issue on appeal was whether Defendant was entitled to rely on the so-called "home or business" exception in the definition of second degree weapon possession despite his prior conviction. The Court of Appeals affirmed, holding that because Defendant had a previous conviction, the exception did not apply. View "People v. Jones" on Justia Law

Defendant, a convicted criminal, was convicted of the class C felony of criminal possession of a weapon in the second degree and sentenced to three and one-half years in prison for possessing a loaded weapon in his home. Defendant appealed, arguing that, while the State did have power to punish him for having an unlicensed handgun in his home, his conviction infringed on his Second Amendment right to keep and bear arms where his punishment was unusually severe. The Appellate Division affirmed the conviction and sentence. The Court of Appeals affirmed, holding that Defendant's sentence did not raise constitutional problems in this case. View "People v. Hughes" on Justia Law

Defendant was arrested for driving while intoxicated. Defendant moved to suppress the evidence found inside his car, arguing that it was obtained by police during an invalid inventory search. Supreme Court denied the suppression motion, and Defendant pled guilty. The Appellate Division affirmed, concluding that the inventory search was improper but that Defendant's guilty plea nonetheless was valid under People v. Lloyd, which recognized exceptions to the principle established in People v. Grant that the harmless error doctrine generally cannot be used to uphold a guilty plea that is entered after the improper denial of a suppression motion. The Court of Appeals reversed, holding that the erroneous denial of Defendant's motion to suppress was not harmless because there was not sufficient independent proof of Defendant's guilt. View "People v. Wells" on Justia Law

This consolidated appeal involved cases involving three defendants, each of whom was convicted of "simple" knowing, unlawful possession of a loaded weapon in addition to one or more other criminal counts. In each case, the trial courts imposed sentences for the weapon possession counts to run consecutively to the sentences for other crimes committed with the same weapon. Defendants appealed. The Appellate Division affirmed in each instance. The Court of Appeals affirmed, holding that because the three defendants completed the crime of possession independently of their commission of the later crimes, consecutive sentencing was permissible. View "People v. Brown" on Justia Law

At issue in these two consolidated appeals was whether, for purposes of determining the sequentiality of a defendant's current and prior convictions under the State's sentence enhancement statutes, the controlling date of sentence for the defendant's prior conviction is the original date of sentence for that conviction or the date of a later resentencing rectifying the flawed imposition of postrelease supervision (PRS). The Court of Appeals held (1) under the circumstances presented in these cases, the date of sentence for a defendant's prior conviction is the original date on which the defendant received a lawful prison term upon a valid conviction for that prior crime, regardless of whether the defendant or government sought resentencing on that conviction to correct an improper imposition of PRS; and (2) therefore, at sentencing for a more recent crime, the defendant's prior conviction qualifies as a predicate felony conviction if the original date of sentence precedes the commission of the present offense. View "People v. Boyer" on Justia Law