Justia New York Court of Appeals Opinion Summaries

The Court of Appeals held that the negligence claims brought in this case involving two separate murders on property owned by the New York City Housing Authority (NYCHA) should advance to a jury trial.Bridget Crushshon and Tayshana Murphy were killed by intruders on the premises of two different public house complexes, owned and operated by the NYCHA, where the victims lived. In two separate cases, Plaintiffs filed negligence lawsuits against NYCHA, asserting that NYCHA had a duty to provide a locking exterior doors to their buildings. While admitting that it had a duty to provide a locking exterior door, NYCHA moved for summary judgment, arguing that it was not a proximate cause of the deaths because the murderers had "targeted" their victims rather than commit crimes of opportunity. The Second Department denied summary judgment in one case, and the First Department granted summary judgment in the other case. The Court of Appeals affirmed the Second Department's denial of summary judgment and reversed the First Department's grant of summary judgment to NYCHA in the two cases, holding that the fact that an attack was "targeted" does not sever the causal chain between a landlord's negligence and a plaintiff's injuries as a matter of law. View "Scurry v. New York City Housing Authority" on Justia Law

The Court of Appeals affirmed the order of the appellate division concluding that the underlying challenge to Local Law No. 9-2014 was not time barred by either a four-month or a six-year statute of limitations, holding that there was no error.Local Law No. 9-2014 was adopted by the Town Board of the Town of Clarkstown in 2014 and purportedly set an eight-year term limit for all Clarkstown elected officials and required a supermajority vote of the Town Board to repeal. Appellees brought this action seeking a determination that the law was invalid because it was not subjected to a referendum of the Town's voters. Appellants filed a motion to dismiss based on statute of limitations grounds. The appellate division declined to dismiss the actions. The Court of Appeals affirmed in each case, holding that, under the circumstances, the actions were not time barred. View "Hoehmann v. Town of Clarkstown" on Justia Law

The Court of Appeals reversed the denial of Defendant's motion to suppress evidence seized as a result of a stop and frisk, holding that the circumstances of this case did not warrant a level three stop and frisk under People v. De Bour, 40 N.Y.2d 210 (1976).Defendant, who was stopped and frisked after he existed a parked car and walked down the street, filed a motion to suppress drugs found on his person as the fruits of an illegal search and seizure. The trial court denied the motion to suppress, and Defendant was subsequently convicted of two counts of criminal possession of a controlled substance in the third degree. The appellate division affirmed. The Supreme Court reversed and directed that the indictment be dismissed, holding that the police officer lacked reasonable suspicion to justify the stop and frisk of Defendant. The Court of Appeals reversed, holding that the minimum standard required to justify a stop and frisk under People v. De Bour, 40 N.Y.2d 210 (1976), was not met in this case. View "People v. Johnson" on Justia Law

The Supreme Court affirmed in part and reversed in part Defendant's criminal convictions, holding that the count of the indictment charging Defendant with aggravated family offense was jurisdictionally defective and must be dismissed but that there was no error as to Defendant's conviction of criminal contempt in the first degree.After a jury trial, Defendant was found guilty of criminal contempt in the first degree, criminal contempt in the second degree, and aggravated family offense. The appellate division modified the judgment by vacating Defendant's conviction of criminal contempt in the second degree and otherwise affirmed. The Supreme Court modified the appellate division order, holding (1) a jurisdictional defect in the aggravated family offense count required that the aggravated family offense count be dismissed; and (2) Defendant was not entitled to relief on his argument that his criminal contempt in the first degree conviction must be vacated on the ground that his trial counsel was ineffective for failing to challenge the legal sufficiency of the evidence supporting that conviction. View "People v. Saenger" on Justia Law

In these consolidated cases in which both plaintiffs sought to recover for injuries sustained during organized sports practices for high school athletic teams and appealed from orders granting Defendants' motions for summary judgment, the Court of Appeals addressed the primary assumption of risk doctrine and held that material questions of fact remained in one case.The two cases considered by the Supreme Court provided an opportunity to apply the principles of the primary assumption of the risk doctrine in the context of organized practice drills for high school athletic teams. The Court rejected the dissent's suggestion to abandon the doctrine and held (1) in the first case, the primary assumption of the risk doctrine applied, and therefore, summary judgment was properly granted; and (2) in the second case, material issues of fact remained to be resolved by a jury. View "Grady v. Chenango Valley Central School District" on Justia Law

The Court of Appeals affirmed the judgment of the Appellate Division dismissing Plaintiffs' claims that Taxi and Limousine Commission and New York City breached the implied covenant of good faith and fair dealing and engaged in deceptive business practices under N.Y. Gen. Bus. Law 349, holding that Plaintiffs failed to state a claim.Plaintiffs, entities that purchased government licenses to operate taxis at an auction, brought this action alleging that Defendants (1) breached the implied covenant of good faith and fair dealing by failing to enforce certain licensing requirements against smartphone applicate-based competitors such as Uber Technologies, Inc. and Lyft, Inc.; and (2) engaged in deceptive business practices in their promotion of the auction. Supreme Court granted in part Defendants' motion to dismiss. The Appellate Division reversed in part and concluded that both claims should be dismissed. The Court of Appeals affirmed, holding (1) Plaintiffs did not adequately plead a claim for breach of the implied covenant of good faith and fair dealing; and (2) Plaintiffs failed to plead the type of conduct covered by N.Y. Gen. Bus. Law 349. View "Singh v. City of New York" on Justia Law

The Court of Appeals reformulated a question certified to it by the United States Court of Appeals for the Eleventh Circuit and concluded that Plaintiff's allegations did not state a cognizable cause of action for breach of the implied contract of good faith and fair dealing.At issue was whether Plaintiff sufficiently pled a cause of action for breach of the implied contract under New York law by alleging that, during a Structured Settlement Protection Act proceeding, the structured settlement obligor and the issuer of an annuity funding the settlement failed to enforce the anti-assignment provisions contained in structured settlement and qualified assignment agreements. The Court of Appeals answered the question, as reformulated, in the negative, holding that Plaintiff failed to meet its burden of proving an implied promise in this case. View "Cordero v. Transamerica Annuity Service Corp." on Justia Law

In this dispute between two Major League Baseball (MLB) teams and their co-owned regional sports network the Court of Appeals affirmed as modified the judgment of the court of appeals affirming the confirmation of a second arbitration award and directed that a money judgment be vacated, holding that the highly sophisticated parties were bound to the terms of their agreement.In this dispute regarding the fair market value of certain telecast rights Plaintiffs sought to vacate an arbitration award granted by the MLB's Revenue Sharing Definitions Committee (RSDC). Supreme Court vacated the arbitration award based on the RSDC's evident partiality, and the appellate division affirmed. After a second hearing, the RSDC entered a second award. Supreme Court affirmed, and the appellate division affirmed. The Court of Appeals affirmed as modified, holding (1) the courts below correctly confirmed the second arbitration award; and (2) the order must be modified because Supreme Court erred by awarding prejudgment interest and rendering a money judgment. View "TCR Sports Broadcasting Holding, LLP v. WN Partner, LLC" on Justia Law

The Court of Appeals held that N.Y. Gen. Mun. Law 205-b does not authorize a claim against a fire district for the negligence of a volunteer firefighter when the firefighter's actions are otherwise privileged and subject to a heightened recklessness standard under N.Y. Veh. & Traf. Law 1104.Plaintiff brought a personal injury action against the Commack Fire District after her vehicle collided with a fire truck owned by the district and operated by a volunteer firefighter. The trial court granted summary judgment to the firefighter on the grounds that Plaintiff had failed to establish that the firefighter acted with reckless disregard but concluded that the District was not entitled to summary judgment on Plaintiff's vicarious liability claim. The appellate division affirmed. The Court of Appeals reversed, holding that when a volunteer firefighter's actions satisfy the conditions set forth in N.Y. Veh. & Traf. Law 1104(e) and are thus privileged, there is no breach of duty or negligence that can be imputed to a fire district under N.Y. Gen. Mun. Law 205-b. View "Anderson v. Commack Fire District" on Justia Law

The Court of Appeals affirmed the judgment of the appellate division affirming the summary denial of Defendant's N.Y. Crim. Proc. Law (CPL) 440 motion, holding that the district court's summary denial of Defendant's motion to vacate his conviction was not an abuse of discretion.After a jury trial, Defendant was convicted of multiple counts of rape and sexual abuse and sentenced to fifty-four years in prison. Several years later, Defendant moved to vacate his conviction pursuant to CPL 440.10, alleging ineffective assistance of counsel and the discovery of new evidence. County Court denied the motion without holding an evidentiary hearing, and the appellate division affirmed. The Court of Appeals affirmed, holding that County Court did not abuse its discretion in denying Defendant's motion without a hearing. View "People v. Hartle" on Justia Law