Justia New York Court of Appeals Opinion Summaries

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

Defendant was convicted for a 2003 drug transaction and sentenced to prison. On November 25, 2009 defendant filed an application for resentencing under the 2009 Drug Law Reform Act (DLRA), CPL 440.46. On December 3, 2009, before the application had been ruled on, she was released on parole. At issue was whether defendant was eligible for resentencing because she was not presently in custody. The court held that a prisoner who applied for resentencing before being paroled was not barred from obtaining resentencing after her release where the statute's plain language only stated that an offender must be in custody when he or she applied for resentencing but did not require that custody continue until the application was decided. View "People v. Santiago" on Justia Law

Defendants committed class B felonies involving narcotics and were sentenced to indeterminate prison terms. All defendants were subsequently paroled, violated their parole, and were sent back to prison. After the enactment of the 2009 Drug Law Reform Act (DLRA), CPL 440.46, defendants applied for resentencing. At issue was whether the DLRA provided relief to reincarcerated parole violators. The court held that prisoners who have been paroled, and then reincarcerated for violating their parole, were not for that reason barred from seeking relief under the statute where the statute's plain language stated no such exception. View "People v. Paulin; People v. Pratts; People v. Phillips " on Justia Law

Claimants in these four cases were convicted of crimes for which they received indeterminate sentences. A statute required that such a sentence include a period of post-release supervision ("PRS"), but in each claimant's case, the sentencing judge failed to pronounce a PRS term. Claimants were nevertheless subjected to PRS, and in three of the four cases, were imprisoned for a PRS violation. They now seek damages from the State, asserting that they were wrongfully made to undergo supervision and confinement. The court held that all of the claims were without merit where the only error in Jonathan Orellanes' case was by the sentencing judge, which was barred by judicial immunity, and where Farrah Donald, Shakira Eanes, and Ismael Ortiz sued for false imprisonment but failed to plead the essential elements. Accordingly, the order of the Appellate Division in each case was affirmed. View "Donald v. State; Eanes v. State; Orellanes v. State; Ortiz v. State" on Justia Law

Defendant was charged with attempted murder, assault, criminal possession of a weapon, and criminal possession of a controlled substance where defendant was arrested for a shooting death, defendant's gray minivan was subsequently searched, and cocaine was recovered from a compartment behind the ashtray of the front console. After a jury convicted defendant of some of the charges, defendant appealed the Supreme Court's denial of his motion to suppress physical evidence. At issue was whether the Appellate Division erred by upholding the denial of suppression on a basis that the Supreme Court had squarely rejected. The court held that the Appellate Division's decision with respect to the suppression was clearly erroneous under People v. LaFontaine where CPL 470.15(1) precluded that court from affirming denial of suppression on the basis of consent because the trial judge ruled in defendant's favor on the issue. Consequently, the court had to decide whether granting suppression would be harmless with respect to defendant's conviction for the other crimes. The court held that there was no reasonable possibility that the evidence supporting the potentially tainted count, a drug possession crime related to the cocaine discovered, had a spillover effect on the guilty verdicts for weapon possession and assault. Accordingly, the order of the Appellate Division should be modified by remitting to the Supreme Court for further proceedings in accordance with the opinion, and as modified, affirmed. View "The People v. Concepcion" on Justia Law