Justia New York Court of Appeals Opinion Summaries

After an incident in Brooklyn where the defendant struck a pedestrian with his vehicle, he was charged by misdemeanor complaint with several offenses, including aggravated unlicensed operation of a motor vehicle in the second and third degrees, unlicensed operation of a motor vehicle, and failure to obey a traffic control signal. The supporting documents contained allegations for the unlicensed operation charges but lacked factual allegations for the failure to obey a traffic signal charge. Later, the prosecution filed an information and a statement of readiness, certifying compliance with statutory requirements for facial sufficiency for all counts, even though the failure to obey a traffic signal charge was facially insufficient.The defendant moved to dismiss the information on grounds of facial insufficiency and statutory speedy trial violations, arguing that the prosecution’s certification under CPL 30.30 (5-a) was inaccurate, thereby invalidating their statement of readiness. The prosecution conceded the insufficiency of the traffic signal count, which was dismissed by the Criminal Court. The court otherwise denied the motion, finding that the statute only required a certification for readiness and did not mandate dismissal of the entire instrument due to inaccuracies in the certification. The Appellate Term affirmed, holding that the statute did not require further remedy beyond dismissal of the insufficient count.The New York Court of Appeals affirmed the Appellate Term’s order. The Court held that CPL 30.30 (5-a) requires only that the prosecution file a certification of facial sufficiency for all counts in a local criminal court accusatory instrument as a condition of readiness. The statute does not provide for invalidation of the statement of readiness or dismissal of the entire instrument when that certification is inaccurate as to a particular count; the appropriate remedy is dismissal of the defective count alone. View "People v Williams" on Justia Law

A county child welfare agency initiated proceedings to terminate a mother's parental rights to her twins, who had been removed from her care at around six months old. The mother was assigned counsel but had not communicated with her attorney prior to the fact-finding hearing. At the hearing, the mother appeared remotely, while her attorney was present in person. The attorney informed the Family Court that he had not discussed the case with his client and intended to remain silent. The court instructed him to participate regardless. Only after the hearing began did counsel request time to speak with the mother. During the proceedings, the mother attempted to represent herself but expressed confusion about the process and later asked to be represented again. The court denied her renewed request for representation and allowed only brief opportunities for her and counsel to communicate.The Family Court determined that the mother had permanently neglected her children and proceeded to the dispositional phase, ultimately terminating her parental rights in favor of adoption by the foster family. The mother appealed. The Appellate Division affirmed the Family Court's decision, finding that the mother had not been denied effective assistance of counsel and that her waiver of counsel was knowing, voluntary, and intelligent.The New York Court of Appeals reviewed the case and concluded that the mother was deprived of her right to the effective assistance of counsel. The Court held that, in proceedings to terminate parental rights, the right to assigned counsel necessarily includes the right to effective assistance of counsel. The Court found that counsel’s failure to communicate with the mother prior to the hearing, and to request an adjournment to do so, lacked any strategic or reasonable justification, thus rendering the representation ineffective and undermining the fairness of the proceedings. The Court of Appeals reversed the order of the Appellate Division and remitted the matter to Family Court for a new hearing. View "Matter of Parker J." on Justia Law

In April 2020, a store manager working for a retail employer contracted COVID-19, followed by a stroke one week later. He alleged that both the infection and the subsequent stroke were caused by exposure to COVID-19 while working in a high-traffic store environment during the early months of the pandemic. The claimant described frequent, close interactions with the public and stated that employer-provided protective measures, such as masks and sneeze guards, were not implemented until mid-April. The claimant also testified that he had minimal contact with others outside of work. Medical evidence linked the stroke to the COVID-19 infection, and it was noted that the claimant lacked typical stroke risk factors.The Workers’ Compensation Law Judge initially established the claim as an occupational disease with a consequential stroke. On review, the New York State Workers’ Compensation Board modified the determination, finding instead that the claimant suffered an accidental injury, not an occupational disease, but otherwise affirmed the compensability of both injuries. The Board applied its “prevalence” framework, which looks to whether the workplace presented an extraordinarily high risk of exposure to COVID-19 due to conditions such as significant public contact in an area where the virus was prevalent. The Appellate Division, Third Department, affirmed the Board’s decision.The New York Court of Appeals affirmed the Appellate Division’s order. The Court held that the Board’s “prevalence” framework is consistent with New York Workers’ Compensation Law as interpreted by prior case law. The Court found that substantial evidence supported the Board’s findings that the claimant’s COVID-19 infection and consequential stroke arose out of and in the course of employment, given the extraordinary risk presented by the claimant’s work environment and the credible medical evidence linking the injuries. The Court rejected the employer’s argument that a specific exposure event must be identified. View "Matter of Aungst v Family Dollar" on Justia Law

Four individuals—three transit workers and one teacher—filed claims for Workers' Compensation benefits in 2020, alleging psychological injuries such as PTSD that resulted from workplace exposure to COVID-19. The Workers' Compensation Board determined that the claimants experienced stress comparable to that faced by other employees in similar roles during the pandemic. Therefore, the Board denied the claims, finding that the stress encountered did not meet the threshold for a compensable "accident" under the Workers' Compensation Law.The Appellate Division, Third Department, reversed the Board’s decisions. It held that the Board erred by not considering each claimant’s individual vulnerabilities and by applying different burdens for psychological injury claims compared to claims for contracting COVID-19 itself. The Appellate Division cited Matter of Wolfe v Sibley, Lindsay & Curr Co., stating that psychological injuries precipitated by psychic trauma should be compensable to the same extent as physical injuries. It further concluded that the Board should apply its “prevalence rule”—which allows proof of an elevated risk via workplace prevalence of COVID-19—to psychological injury claims as well as physical injury claims.Upon review, the New York Court of Appeals reversed the Appellate Division’s orders and reinstated the Board’s decisions. The Court of Appeals held that the Board is not required to consider a claimant’s particular vulnerabilities when evaluating psychological injury claims. It clarified that, at the relevant time, claimants needed to show that their workplace stress was greater than that ordinarily experienced by similarly situated workers in the normal work environment for the injury to be deemed accidental. The Court found substantial evidence supporting the Board’s conclusion that the claimants’ stress was not exceptional, and ruled that the prevalence of COVID-19 in the workplace does not alter the legal standard for compensable psychological injury. View "Matter of McLaurin v New York City Tr. Auth." on Justia Law

On July 30, 2022, police responded to Omar Johnson's home after a 911 call reported domestic violence. While investigating, officers discovered a loaded pistol in Johnson's moped and determined he did not possess a valid firearm license. Johnson was arrested and indicted for multiple counts of criminal weapon possession and possession of ammunition. These events occurred shortly after the U.S. Supreme Court issued its decision in New York State Rifle & Pistol Association, Inc. v. Bruen, but before New York amended its firearm licensing laws.Johnson moved to dismiss the indictment in the Supreme Court of New York County, arguing that Bruen invalidated the state's "proper cause" requirement for firearm licenses and, by extension, rendered the entire licensing scheme unconstitutional. The Supreme Court denied the motion, holding that Johnson lacked standing because he had not applied for a license and that Bruen invalidated only the "proper cause" requirement, not the entire scheme. Johnson pleaded guilty, waiving his right to appeal, and was sentenced to probation. On appeal, the Appellate Division, First Department, affirmed, concluding that the appeal waiver was valid, Johnson lacked standing, and his conviction was not unconstitutional under Bruen.The New York Court of Appeals reviewed the case. It held that Johnson’s facial constitutional challenge to the licensing scheme was not waived by his appeal waiver, as such claims implicate broader societal interests. The Court determined that Johnson had standing to raise a facial challenge, even though he never applied for a license, because his conviction directly resulted from the licensing scheme. On the merits, the Court concluded that Bruen’s invalidation of only the "proper cause" requirement did not render the entire New York firearm licensing scheme unconstitutional, as the requirement is severable. The order of the Appellate Division was affirmed. View "People v Johnson" on Justia Law

Several insurance companies initiated a federal lawsuit against a licensed acupuncturist, three professional service corporations under his control, and two unlicensed individuals. The insurers sought a declaration that one of the corporations was not entitled to no-fault insurance reimbursement for services rendered, alleging the corporation engaged in a scheme to pay unlicensed individuals for patient referrals. The payments allegedly violated New York’s professional conduct rules but did not involve the transfer of control over the corporation to unlicensed persons.The United States District Court for the Eastern District of New York found that the acupuncturist and his corporations had engaged in an unlawful fee-splitting and kickback scheme, violating New York law. The court ruled that this professional misconduct rendered the corporation ineligible for no-fault reimbursement under the relevant Department of Financial Services (DFS) regulation and granted summary judgment for the insurers. On appeal, the United States Court of Appeals for the Second Circuit agreed that the referral fees were paid but found it unclear whether this type of professional misconduct made the provider ineligible for reimbursement under the regulation. It certified to the New York Court of Appeals the question of whether such misconduct, absent ceding control to unlicensed persons, permits denial of no-fault benefits.The New York Court of Appeals held that the DFS regulation does not authorize insurers to deny no-fault reimbursement based solely on a provider’s alleged professional misconduct, such as paying for patient referrals, unless that misconduct amounts to a failure to meet a foundational licensing requirement—specifically, surrendering control of the professional practice to unlicensed individuals. The court deferred to DFS’s longstanding interpretation that only licensing violations resulting in loss of eligibility to practice, as determined by regulators, justify denial of reimbursement. The court answered the certified question in the negative. View "Government Employees Ins. Co. v Mayzenberg" on Justia Law

A nonprofit religious organization based in Queens purchased a 73-acre parcel in the Town of Callicoon, Sullivan County, in 2018. Although the organization originally intended to use the property as a retreat center, testimony established that its actual use involved farming vegetables on about one cleared acre for charitable distribution to low-income residents in Queens. Occasional overnight stays involved religious activities, but there was no evidence of regular organized religious services or use as a retreat center. The Town Supervisor, who lived nearby and farmed part of the property without a formal agreement, confirmed the farming use but did not observe overnight retreats.After the Town Assessor denied a religious use tax exemption for the property for the 2021 tax year, the organization filed a grievance complaint, which was denied by the Town’s Board of Assessment Review. The organization then initiated an RPTL article 7 proceeding in Supreme Court, challenging the denial. A similar process occurred for the 2022 tax year, and both proceedings were joined. Supreme Court held a nonjury trial, found all witnesses credible, credited the organization’s testimony about actual use, and granted the petitions for both tax years, concluding the property was exempt. The Appellate Division affirmed this decision, with one Justice dissenting.The New York Court of Appeals reviewed the case. It held that the lower courts applied the correct legal standards: the burden to prove entitlement to exemption rests with the party seeking it, while the burden to prove a zoning violation rests with the municipality. The Court of Appeals found record support for Supreme Court’s factual findings and concluded that the Town failed to prove a zoning violation sufficient to defeat the exemption for both years. The order of the Appellate Division was affirmed, with costs. View "Matter of First United Methodist Church in Flushing v Assessor, Town of Callicoon" on Justia Law

The defendant was charged with several offenses after a violent confrontation with a 20-year-old escort in his Queens home, leading to a police investigation that uncovered weapons, ammunition, forgery devices, and other items on the premises. During the jury trial, an alternate juror replaced a dismissed juror, leaving no further alternates. After the jury began deliberations, the foreperson reported an encounter outside his home with a man acting "on behalf of" the defendant, who provided court documents and claimed the defendant’s innocence. The foreperson, shaken by the incident, felt unable to remain impartial and was discharged from the jury.The Supreme Court, Queens County, held a hearing and found by clear and convincing evidence that the defendant orchestrated the confrontation with the foreperson, including feigning illness to leave court early. The court determined that this egregious misconduct was intended to improperly influence the jury. With no alternates available, the court, relying on forfeiture principles from prior cases, concluded the defendant forfeited his constitutional right to a jury of 12, and proceeded with 11 jurors. The 11-person jury found the defendant guilty on some counts and acquitted him on others.The Appellate Division affirmed the conviction, holding that the defendant’s "egregious" misconduct warranted forfeiture of the right to a 12-person jury. A dissenting Justice argued that such forfeiture should only occur in extreme circumstances, analogizing the right to a jury of 12 to the right to counsel. Upon review, the New York Court of Appeals held that a defendant who engages in egregious conduct affecting a sworn juror after deliberations begin, resulting in discharge and no alternates remaining, forfeits the right to a jury of 12. The court affirmed the trial court’s exercise of discretion in proceeding to verdict with 11 jurors. View "People v Sargeant" on Justia Law

Following the September 11, 2001 terrorist attacks, the New York Legislature enacted Article 8-A of the Workers' Compensation Law to allow both employees and volunteers who participated in rescue, recovery, and cleanup operations at designated sites to seek compensation for health conditions resulting from exposure to hazardous materials. In this case, a volunteer who had received lifetime workers’ compensation benefits for conditions contracted during his service died in July 2016. His spouse filed a claim for death benefits with the Workers' Compensation Board (WCB) more than two years after his death.A Workers’ Compensation Law Judge initially awarded death benefits to the claimant. However, after administrative review requested by the Uninsured Employers’ Fund, the WCB disallowed the award, concluding that the death benefits claim was untimely under Workers’ Compensation Law § 28’s two-year statute of limitations. The Board found that Article 8-A did not exempt such claims from the two-year limit, and that the claim was not for an occupational disease. The Appellate Division, Third Department, affirmed the Board’s decision, holding that the statutory extension for filing claims under Article 8-A (Workers’ Compensation Law § 168) applies only to claims filed by “participants” themselves, not by their survivors or beneficiaries. The dissent would have remitted the matter for further proceedings under Workers’ Compensation Law § 163, regarding notice requirements.The New York Court of Appeals affirmed the Appellate Division’s order. The Court held that the statutory extension of time for filing certain claims under Workers’ Compensation Law § 168 applies solely to claims brought by statutorily defined “participants,” and not to claims brought by their survivors or beneficiaries. Consequently, the spouse’s claim for death benefits was barred by the two-year limitation period in Workers’ Compensation Law § 28. View "Matter of Garcia v WTC Volunteer" on Justia Law

Six residents of the Town of Newburgh sued the Town and its Town Board, alleging that the Board’s at-large electoral system unlawfully diluted the votes of Black and Hispanic residents, in violation of Section 17-206 of the New York Voting Rights Act (NYVRA). The plaintiffs argued that the method of electing all five Town Board members at-large prevented Black and Hispanic voters, who together made up about 40% of the population, from electing their preferred candidates or influencing election outcomes. They sought a court declaration that the at-large system violated the NYVRA and an injunction requiring the Town to implement a different electoral system.The Town of Newburgh moved for summary judgment, arguing that Section 17-206 was facially unconstitutional under the Equal Protection Clauses of the U.S. and New York Constitutions, and that its current election system complied with the NYVRA. The Supreme Court, Orange County, granted the Town’s motion, holding that the Town could challenge the statute because it allegedly could not comply with the NYVRA without violating equal protection, and declared the provision—and the entire NYVRA—unconstitutional. The Appellate Division reversed, holding that the Town lacked capacity to bring this challenge since it had not shown that compliance with the NYVRA would force it to violate equal protection, and that the Supreme Court erred in invalidating the statute.The New York Court of Appeals reviewed the case and held that the Town of Newburgh, as a political subdivision created by the State, could not bring a facial constitutional challenge to the NYVRA's vote-dilution provision. The court reaffirmed the longstanding rule that political subdivisions generally lack authority to challenge state laws unless a narrow exception applies, and found that no such exception was met here. The Appellate Division’s order was affirmed. View "Clarke v Town of Newburgh" on Justia Law