Justia New York Court of Appeals Opinion Summaries

The Court of Appeals reversed the decision of the Appellate Division affirming Defendant's conviction for second-degree rape in satisfaction of the indictment against him, holding that the Appellate Division misinterpreted the test in People v. Taranovich, 37 N.Y.2d 422, (1975), for deciding whether pretrial delays rise to the level of a constitutional deprivation of the right to a speedy trial.Defendant's convictions stemmed from the sexual assault of a fourteen-year-old girl. The time between the crime and Defendant's indictment was almost eight years. Defendant moved to dismiss the indictment, arguing that the delay in prosecution deprived him of his state and federal constitutional right to due process. County Court denied the motion to dismiss, and Defendant pled guilty. The Appellate Division affirmed. The Court of Appeals reversed, holding that the Appellate Division misinterpreted the Tranovich framework and that remand was required for a factual and legal review made under the proper framework. View "People v. Johnson" on Justia Law

The Court of Appeals affirmed, as modified in accordance with this opinion, the order of the appellate division vacating Defendant's conviction of promoting prostitution in the second degree and otherwise affirming his convictions, holding that Defendant did not make a knowing, voluntary and intelligent waiver of the right to counsel.Defendant was indicted on several sex trafficking and related counts. Defendant represented himself, with varying levels of assistance from his legal advisors, through pretrial motion practice and during a pretrial suppression hearing. The appellate division vacated Defendant's conviction of second-degree promoting prostitution and otherwise affirmed, thus rejecting Defendant's argument that he was deprived of his right to counsel when he was allowed to proceed pro se at pretrial hearings. The Court of Appeals affirmed as modified, holding (1) Defendant's waiver of the right to counsel was not knowing, voluntary, and intelligent; and (2) Defendant was entitled to remittal to Supreme Court for an opportunity to make whatever pretrial motions were, or could have been, made during that period. View "People v. Baines" on Justia Law

The Supreme Court reversed the order of the appellate decision affirming the judgment of the trial court convicting Defendant of two counts of robbery in the second degree and assault in the second degree, holding that the trial judge erred in replacing a trial juror with an alternate following that discharge from service.Prior to the start of deliberations at trial, the court discharged the alternate jurors. Thereafter, a trial juror was removed for alleged misconduct. The trial court decided to recall and seat one of the discharged alternates, after which Defendant was convicted. The Supreme Court reversed the conviction, holding (1) once the court has clearly stated on the record that an alternate juror has no further responsibilities in the case, the alternate juror is discharged; (2) where the alternate jurors have been discharged, the court's sole remedy is to declare a mistrial; and (3) the alternate jurors were discharged in this case, and therefore, the trial judge erred in reseating the alternate juror. View "People v. Murray" on Justia Law

The Court of Appeals reversed the order of the Appellate Tern affirming Defendant's conviction of criminal possession of a controlled substance in the seventh degree in satisfaction of the accusatory instrument, holding that the accusatory instrument failed to give Defendant sufficient notice of the charged crime.Defendant was charged with possession of a controlled substance in the seventh degree for possessing an illegal synthetic cannabinoid. On appeal, Defendant argued that the misdemeanor complaint was jurisdictionally defective because it failed to allege that he possessed one of the synthetic cannabinoid substances listed in N.Y. Public Health Law 3306 (g). The Appellate Division affirmed. The Court of Appeals reversed, holding (1) the misdemeanor to which Defendant pleaded guilty failed to allege a sufficient factual basis to conclude that the substance Defendant possessed was illegal; and (2) dismissal of the remaining count was appropriate. View "People v. Hill" on Justia Law

The Court of Appeals reversed the order of the Appellate Term insofar as appealed from in this criminal case, holding that the court mistakenly relied on amended language in granting Defendant's motion to dismiss the accusatory instrument.Defendant was charged in a single accusatory instrument with three misdemeanor counts and three traffic infractions. Defendant moved to dismiss the accusatory instrument on speedy trial grounds under N.Y. Crim. Proc. (CPL) 30.30. The court denied the motion, and a jury convicted Defendant. During the pendency of Defendant's appeal, the legislature amended CPL 30.30 to add 30.30(1)(e), which states that the term "offense" includes traffic infractions for the purpose of section 30.30(1). The Appellate Term granted Defendant's motion to dismiss the accusatory instrument. The Court of Appeals reversed, holding that CPL 30.30(1)(e) had no application to Defendant's direct appeal from his judgment of conviction because the legislature did not mandate retroactive application of the newly-worded CPL 30.30. View "People v. Galindo" on Justia Law

The Court of Appeals reversed Defendant's conviction of murder in the second degree and criminal possession of a weapon in the second degree, holding that the effect of the trial judge's erroneous evidentiary rulings in this case deprived Defendant of his constitutional right to present a defense.During trial, the court precluded certain evidence proffered by Defendant in support of his justification defense. The court charged the jury on Defendant's justification defense. The jury rejected the defense and convicted Defendant. The Appellate Division reduced Defendant's sentence and otherwise affirmed. The Court of Appeals reversed, holding that a jury should have been allowed to hear and assess the excluded information and then to weigh all of the relevant evidence before reaching a verdict. View "People v. Deverow" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of fraudulent accosting and sentencing him to time served, holding that the complaint was facially sufficient.On appeal, Defendant argued that the term "accost" in N.Y. Penal Law 165.30(1) should be narrowly construed to require "a physical approach and an element of aggressiveness or persistence" that is "directed toward a specific individual rather than the public at large." The Supreme Judicial Court disagreed and affirmed, holding that the accusatory instrument contained factual allegations sufficient to establish reasonable cause that Defendant accosted the potential victims of the scam leading to his conviction. View "People v. Mitchell" on Justia Law

The Court of Appeals reversed the judgment of the Appellate Division reversing Defendant's convictions for attempted use of a child in a sexual performance and other offenses and holding that a new trial was required based on the admission of certain screenshots, holding that the trial court acted within its discretion in determining that the People properly authenticated the screenshots.Defendant, a high school volleyball coach, was charged with several offenses stemming from allegations that Defendant engaged in injurious acts toward a child by sending numerous text massages containing sexual content to a player on his team. The messages were found by the victim's boyfriend, who took screenshots of them and forwarded them to the victim's mother. At issue was the trial court's denial of Defendant's motion to preclude the admission of prints of six of the screenshots on the grounds they were not properly authenticated. The Appellate Division reversed Defendant's convictions for all charges, holding that a new trial was required based on the admission of the screenshots. The Court of Appeals reversed, holding that there was no abuse of discretion as a matter of law in the court's determination that the screenshots of the text messages were sufficiently authenticated or in the admission of the screenshots into evidence. View "People v. Rodriguez" on Justia Law

The Court of Appeals affirmed Defendant's conviction of murder in the first degree and robbery in the first degree, holding that there was no evidentiary error in the proceedings below.At issue on appeal was the admissibility of DNA mixture interpretation evidence generated by the TrueAllege Casework System and whether Supreme Court abused its discretion in finding that TrueAllele's use of the continuous probabilistic genotyping approach to generate a statistical likelihood ratio of a DNA genotype is generally accepted in the relevant scientific community. The Court of Appeals affirmed, holding (1) the trial court did not abuse its discretion in determining that TrueAllele was generally accepted under the Frye standard; and (2) there was no error in the court's denial of Defendant's request for discovery of the TrueAllele source code. View "People v. Wakefield" on Justia Law

The Court of Appeals affirmed the order of the appellate division affirming Defendant's conviction, entered pursuant to a guilty plea, to the class A misdemeanor of criminal possession of a controlled substance in the seventh degree, holding that Defendant's claim on appeal was unpreserved for review.On appeal, Defendant challenged the voluntariness of his guilty plea, asserting that the court, in its plea colloquy, failed to advise him that the twenty days of community service to be imposed would be a condition of a one-year conditional discharge sentence. The Court of Appeals affirmed the determination of the appellate division that Defendant's claim was unpreserved, holding that because Defendant failed to protest or otherwise seek to withdraw his guilty plea prior to the imposition of his sentence his claim on appeal was unpreserved for the Court of Appeals' review. View "People v. Bush" on Justia Law