Justia New York Court of Appeals Opinion Summaries

The primary issue in these appeals was whether the jury verdicts convicting defendants of assault but acquitting them of criminal possession of a weapon were legally repugnant. The court concluded that, based on the instructions that were given to the juries and viewed from a theoretical perspective without regard to the evidence presented at defendants' trials, it was possible for the juries to acquit defendants of weapon possession but convict them of assault because the former crime contained an essential element that the latter did not: possession. Because the repugnancy analysis required the court to review the elements of the offenses as charged to the jury without regard to the proof that was actually presented at trial, the court could not say that the convictions were repugnant. Therefore, under the People v. Tucker test, the court held that, based on the instructions that were used to the juries, the verdicts in these cases need not be invalidated. In Muhammad, the order of the Appellate Division was affirmed. In Hill, the order of the Appellate Division was modified by remitting to that court for further proceedings. View "People v. Muhammad; People v. Hill" on Justia Law

Defendant was convicted of assault in the first degree and sentenced to 25 years imprisonment to be followed by 5 years postrelease supervision. In this case, turning on the accuracy of eyewitnesses' recognition of an assailant's partially concealed face, at issue was whether two additional eyewitness identifications sufficiently corroborated the victim's identification of defendant, so as to render expert testimony on eyewitness recognition memory unnecessary. The court held that they did not and that it was error to exclude much of the proposed testimony. Accordingly, the order of the Appellate Division should be reversed and a new trial ordered. View "People v. Santiago" on Justia Law

Defendant was convicted of murdering his father and the attempted murder of his mother while they slept. On appeal, defendant claimed that his federal constitutional right to confront the witnesses against him was violated by the admission at his criminal trial of testimony that his gravely injured mother nodded affirmatively when asked by the police if he was her assailant. The court held that, even assuming without deciding, that the testimony about the nod was constitutionally infirm, any error was harmless beyond a reasonable doubt where there was overwhelming evidence that placed defendant at the family home when the crimes for which he was convicted were committed there. View "People v. Porco" on Justia Law

Defendant was convicted of four counts of criminal possession of a forged instrument in the second degree. At issue was whether the evidence in this case was legally sufficient to convict defendant of criminal possession of a forged instrument in the second degree. The court held that the evidence adduced at trial established more than defendant's knowing possession of four forged instruments, it provided a solid basis for the jury to infer that defendant had the requisite intent to defraud, deceive, or injure and for it to conclude rationally that defendant was guilty beyond a reasonable doubt. Accordingly, the judgment was affirmed. View "People v. Rodriguez" on Justia Law

Defendants were charged with crimes related to the sexual abuse of a minor. At issue was whether prior consistent statements alleging sexual abuse were properly admitted under the prompt outcry rule or, alternatively, in the Rosario case, to rebut a claim of recent fabrication. The court held that, in both appeals, the Appellate Division's decision was affirmed, which concluded that the prior consistent statement was inadmissible in Rosario, and admissible in Parada. View "People v. Rosario; People v. Parada" on Justia Law

The common question in these appeals was whether the courts fulfilled their responsibility to make a "searching inquiry" before allowing defendants to give up the right to a lawyer and conduct their defenses pro se. The court held that, in both cases, the inquiries were deficient because defendants were not adequately advised of the dangers and disadvantages of self-representation. View "The People v. Crampe; The People v. Wingate" on Justia Law

Following a nonjury trial, the County Court acquitted defendant of intentional assault in the first degree, but convicted her of second-degree reckless assault and endangering the welfare of a child. On appeal, defendant argued that the evidence was legally insufficient to support her conviction for reckless assault. The court held that the order of the Appellate Division should be modified by reducing defendant's conviction for reckless assault in the second degree to criminally negligent assault in the third degree, and by remitting to the Appellate Division for further proceedings. View "The People v. Brown" on Justia Law

Defendant was charged with criminal possession of a weapon in the third degree. At issue was whether the County Court's error in sustaining the prosecutor's objection to defense counsel's question of defendant was harmless. The court held that the Appellate Division properly found that the County Court erred when it denied defendant an opportunity to explain fully the statements he made while in police custody since defendant's statements were both pertinent and probative. The court held, however, that the error was not harmless. The court held that defendant's remaining contentions lacked merit. The order was reversed and a new trial ordered. View "The People v. Robinson" on Justia Law

Benito Acevedo was convicted of criminal sale of controlled substance in the third degree and possession of a controlled substance in the third degree and sentenced as a predicate felony offender with a prior violent felony to a prison term of six years and three years of post-release supervision. Dionis Collado was convicted of two counts of second degree robbery and was then adjudged a second violent felony offender and sentenced to concurrent eight-year prison terms. At issue was whether a resentencing sought by a defendant to correct an illegally lenient sentence was effective to temporally resituate the sentence and thus alter the underlying conviction's utility as a predicate for enhanced sentence. The court held that the decisive feature in these cases was that the sentencing errors defendants sought to correct by resentencing were errors in their favor. The court also held that resentence was not a device appropriately employed simply to alter a sentencing date and thereby affect the utility of a conviction as a predicate for the imposition of enhanced punishment. Therefore, the Sparber relief defendants obtained was not effective to avoid the penal consequences of reoffending. Accordingly, the judgment of the Appellate Division was reversed and the order of the Supreme Court reinstated. View "People v. Acevedo; People v. Collado" on Justia Law

This case stemmed from a dispute over the status of a negotiated settlement agreement pertaining to New York City's duty to provide mental health services to certain inmates in its jails. At issue was whether the terms of the agreement expired before plaintiffs filed a motion in Supreme Court seeking to extend the City's obligations. Applying the state's traditional principles of contract interpretation, the court held that plaintiffs sought relief prior to termination of the settlement agreement and their motion was therefore timely filed. View "Brad H., et al. v. The City of New York, et al." on Justia Law