Justia New York Court of Appeals Opinion Summaries

Articles Posted in New York Court of Appeals
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At issue in this case was the constitutionality of the HAIL Act, which regulates medallion taxicabs and livery vehicles. The Act's stated aim is to address certain mobility deficiencies in the City of New York. Plaintiffs, medallion owners and their representatives, challenged the HAIL Act on the ground that the regulation of yellow cab and livery enterprises is a matter of local concern. Specifically, Plaintiffs argued that the Act violates the State Constitution's Municipal Home Rule Clause, the Double Enactment Clause, and the Exclusive Privileges Clause. Supreme Court entered a judgment nullifying the Act and declaring that it violated the Constitution. The Court of Appeals reversed, holding that the HAIL Act does not violate the Municipal Home Rule Clause, the Double Enactment Clause, or the Exclusive Privileges Clause. View "Greater N.Y. Taxi Ass'n v. State" on Justia Law

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The Wicks Law requires public entities seeking bids on construction contracts to obtain separate specifications for three subdivisions of the work to be performed. Until 2008 when the law was amended to raise the threshold, the Wicks Law applied to contracts whose cost exceeded $50,000. The new, higher thresholds, unlike the old one, were not uniform throughout the State. Plaintiffs claimed, inter alia, that the amendments violated the Home Rule section of the State Constitution by unjustifiably favoring the eight counties with higher thresholds. Supreme Court dismissed the complaint, holding that Plaintiffs lacked standing to assert the Home Rule cause of action and that, in any event, the challenged amendments did not violate the Home Rule section because they "were enacted in furtherance of and bear a reasonable relationship to a substantial State-wide concern." The Appellate Division affirmed. The Court of Appeals affirmed as modified, holding (1) at least one plaintiff had standing to assert the Home Rule claim, but that claim failed on the merits; and (2) most of Plaintiffs' other claims failed, but four causes of action challenging the apprenticeship requirements as applied to out-of-state contracts should be reinstated. View "Empire State Chapter of Associated Builders & Contractors v. Smith" on Justia Law

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In 2003, School District announced to its faculty and staff, who were represented by Union, that the district's practice of reimbursing Medicare Part B premiums of retirees sixty-five years or older would be terminated. Union filed a contract grievance, alleging that School District violated the collective bargaining agreement (CBA) between the parties by failing to negotiate cancellation of Medicare Part B premium reimbursement. After a hearing, an arbitrator concluded that the district was not contractually obligated to reimburse Medicare Part B premiums. The Union also filed an improper practice charge with the New York State Public Employment Relations Board (PERB). An ALJ concluded that School District had violated N.Y. Civ. Serv. Law 209-a(1) because the district promised in the past to reimburse current employees' post-retirement Medicare Part B premiums. PERB denied the district's exceptions and affirmed the ALJ. The Court of Appeals affirmed, holding (1) it was reasonable for PERB not to defer to the arbitrator's findings relating to past practice; (2) PERB's decision in regard to past practice was supported by substantial evidence; and (3) the continued Medicare Part B premium reimbursement was not unconstitutional. View "Chenango Forks Cent. Sch. Dist. v. State Pub. Employee Relations Bd." on Justia Law

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Defendant was charged with sex-related crimes. In his summation, defense counsel argued that parts of Complainant's testimony were incredible because a statement Complainant gave to a police officer who responded to her 911 call omitted a number of details that were in Complainant's later testimony and that the People should have called the officer to testify. The trial court directed the jury to disregard counsel's missing witness argument. After summations, defense counsel moved for a mistrial on the basis of this ruling. The court denied the motion, stating that counsel should have asked for a missing witness instruction if he wanted to make a missing witness argument. Defendant was then convicted of criminal sexual act, criminal contempt, and assault. The Appellate Division affirmed, concluding that there was no "good faith basis" for comment by defense counsel on the People's failure to call the officer. The Court of Appeals affirmed, holding that the trial court erred in prohibiting Defendant from making a missing witness argument but that the error was harmless. View "People v. Thomas" on Justia Law

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Defendant was arrested for robbery. An attorney from the Legal Aid Society represented Defendant at trial. Prior to opening statements, defense counsel alerted the court to a possible conflict of interest arising from counsel's previous representation of Franklin DeJesus, whom it was rumored to have committed the robbery. After internal discussions with the trial judge, defense counsel proceeded with the case. The jury found Defendant guilty of first-degree robbery. After Defendant's conviction, Legal Aid moved to set aside the verdict based on newly discovered evidence consisting of DeJesus' alleged jailhouse confession to Defendant. Supreme Court denied the motion. The Appellate Division affirmed, determining that Defendant had not been deprived of his right to effective legal assistnce due to Legal Aid's dual representation of Defendant and DeJesus because there was no conflict between their interests. The Court of Appeals affirmed, holding that Defendant did not adequately demonstrate that he received less than meaningful representation, as the record did not establish that the potential conflict actually affected the presentation of the defense or otherwise impaired counsel's performance. View "People v. Sanchez" on Justia Law

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Defendant was charged with intentional murder and second-degree weapon possession. Defendant's first trial resulted in a hung jury and mistrial. Defendant was re-tried, and the jury convicted Defendant as charged. After the jury verdict was handed down, the presiding judge, Justice Carter, issued an order recusing himself because of his discovery that he knew the uncle of the victim. In the meantime, Defendant filed a motion seeking an order granting his prior applications for a trial order of dismissal. Justice Palmieri, the judge to whom the case was reassigned, denied Defendant's motion. Defendant appealed, arguing that the evidence was legally insufficient to prove his guilt and that N.Y. Judiciary Law 21 barred any other judge than Justice Carter from deciding his motion. The Appellate Division affirmed. The Court of Appeals affirmed, holding (1) legally sufficient evidence supported Defendant's convictions; and (2) Judiciary Law 21 did not bar Justice Palmieri from ruling on the motion at issue. View "People v. Hampton" on Justia Law

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After a trial, Defendant was convicted of murder in the second degree. Defendant appealed, challenging his custodial interrogation that lasted almost fifty hours. Defendant's previously filed motion to suppress was granted to the extent of excluding the statements Defendant made during the "marathon interrogation." On appeal, Defendant argued that his suppression motion should have been granted not only to the statements made during the interrogation itself but to the further extent of suppressing his subsequent inculpatory statements. The appellate division held that Defendant's subsequent statements, which were made approximately ten hours after the lengthy interrogation were sufficiently attenuated from the prior interrogation to conclude that they were not the product of official compulsion. The Court of Appeals reversed and ordered a new trial, holding that, as a matter of law, the taint of the wrongful police action was not attenuated. View "People v. Guilford" on Justia Law

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The Empire Zones Program Act offered state tax incentives designed to enhance business development in the state. In 2009, the program was amended to introduce two new criteria businesses must meet to retain their certificates for the program. Plaintiffs were five businesses which were certified under the program prior to 2008. In 2009, Plaintiffs were decertified from the program for failing to meet the new criteria. Supreme Court granted summary judgment for the James Square plaintiffs, concluding that the state defendants acted without legal authority when they applied the new criteria for the program retroactively. The legislature subsequently clarified its intention, stating that the 2009 amendments to the program were to be applied retroactively to January 1, 2008. Supreme Court adhered to its prior determination, declaring that the legislature's clarification as applied was unconstitutional. The Appellate Division affirmed. Regarding the additional plaintiffs, the Appellate Division modified Supreme Court's holding to the extent of granting Plaintiff's petitions seeking a declaration that the 2009 amendments could not be applied retroactively to January 1, 2008. The State appealed. The Court of Appeals affirmed the Appellate Division's determinations in all five cases that the 2009 amendments should not be applied retroactively. View "James Square Assocs. LP v. Mullen" on Justia Law

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Plaintiffs purchased furniture from the Fortunoff Department Store. Along with the furniture, Plaintiffs purchased a protection plan. The plan was a contract in which Valspar Corporation agreed to provide service for damages to the furniture during the contract period. The plan contained a store closure provision providing that if the store location where customers purchased furniture closed, the purchase price of the plan would be refunded. Fortunoff subsequently closed, and Valspar tendered Plaintiffs a refund of their payment made to the plan. Plaintiffs brought a diversity action against Valspar for breach of contract under N.Y. Gen. Bus. Law 395, which forbids the termination before expiration of any "maintenance agreement covering parts and/or service" and for damages under N.Y. Gen. Bus. Law 349, claiming that section 395 rendered the store closure provision ineffective and that, by denying claims based on this provision, Valspar breached its contracts with Plaintiffs. The district court dismissed the case. The Court of Appeals accepted certification to answer questions of law and held (1) section 395(a) does not make contract clauses that contradict its terms null and void; and (2) a violation of section 395(a) alone does not give rise to a cause of action under section 349. View "Schlessinger v. Valspar Corp." on Justia Law

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Defendant was charged with burglary in the second degree and grand larceny in the third degree for stealing property from the apartment of Complainants, a husband and wife. The wife spoke Cantonese. Prior to her testimony at trial, the court arranged for a state-employed court interpreter to translate the wife's testimony into English. Because the interpreter was acquainted with Complainants, defense counsel requested that the trial court replace the interpreter. The court denied the request. Defendant was subsequently found guilty as charged. The appellate division affirmed. The Court of Appeals affirmed, holding that, on the facts of this case, the trial court did not abuse its discretion in denying Defendant's request that the court reporter be removed. View "People v. Lee" on Justia Law