Justia New York Court of Appeals Opinion Summaries

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 declared void the legislature's congressional and state senate maps, holding that judicial oversight is required to facilitate the expeditious creation of constitutionally-conforming maps for use in the 2022 election and to safeguard New Yorkers' constitutionally-protected right to a fair election.In 2022, the first redistricting cycle to follow the adoption of 2014 amendments, a stalemate within the Independent Redistricting Commission resulted in a breakdown in the process for submission of electoral maps to the legislature. The legislature responded by creating and enacting maps that failed to follow the 2014 constitutional reforms. Petitioners brought this action alleging that the process by which the 2022 maps were enacted was constitutionally defective. Supreme Court agreed and declared the maps void under the State Constitution. The Court of Appeals agreed, holding (1) the legislature's failure to follow the prescribed constitutional procedure required invalidation of the congressional and state senate maps; and (2) there was record support for the determination that the district lines for congressional races were drawn with an unconstitutional partisan intent. View "Harkenrider v. Hochul" 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 reversed the judgment of the trial court awarding damages in favor of Plaintiff alleging that a commercial talcum powder that his deceased wife used daily for a period of more than ten years during the 1960s and early 1970s proximately caused his wife's illness, holding that Plaintiff's proof of causation was insufficient as a matter of law.In 2016, the decedent passed away. Plaintiff, her husband, sued Defendant, alleging that Defendant supplied another company with talc contaminated with asbestos that was then used in a commercial talcum powder. After a trial, the jury returned a verdict in Plaintiff's favor. The appellate division modified the judgment in connection with the damages awarded but otherwise affirmed. The Court of Appeals reversed, holding that Plaintiff's proof failed as a matter of law to meet the test for proving causation in toxic tort cases. View "Nemeth v. Brenntag North America" on Justia Law

The Court of Appeals held that separate schedule loss of use (SLU) awards for different injuries to the same statutory member are contemplated by N.Y. Work. Comp. Law **(WCL) 15 and that, when a complainant proves that the second injury, considered by itself without consideration of the first injury, has caused an increased loss of use, the claimant is entitled to an SLU award commensurate with that increased loss of use.At issue in these consolidated appeals was whether, under WCL 15, a claimant's SLU award must be reduced by the percentage loss determined for a prior SLU award to a different subpart of the same body member enumerated in section 15. The Court of Appeals reversed the judgment below, holding that separate SLU awards for a member's subparts are authorized by statute. View "Johnson v. City of New York" on Justia Law

The Court of Appeals reversed the order of the Appellate Division modifying the order of Supreme Court by granting Plaintiff summary judgment on his claim brought under N.Y. Labor Law 241(6), holding that the section 241(6) claim must be dismissed.Plaintiff was struck by a power buggy while working at the World Trade Center Transportation Hub construction site owned by the Port Authority of New York and New Jersey (Port Authority). Plaintiff filed this action against the Port Authority, bringing claims under N.Y. Labor Law 241(6) and N.Y. Labor Law 200(1). Supreme Court granted the Port Authority summary judgment on the section 200(1) claim but denied summary judgment on the section 241(6) claim. The Appellate Division modified by granting Plaintiff summary judgment on the section 241(6) claim. The Court of Appeals reversed, holding that 12 NYCRR 23-9.9(a) does not set forth a concrete specification sufficient to give rise to a non-delegable duty under section 241(6). View "Toussaint v. Port Authority of N.Y. & N.J." 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

The Court of Appeals reiterated that plaintiffs must establish that a municipality owed them a special duty when they assert a negligence claim based on actions taken by the municipality acting in a governmental capacity and that plaintiffs may establish a special duty when a municipality's police force plans and executes a no-knock search warrant at a person's residence.Plaintiff bought this action in federal court against the City of Binghamton and its police department, arguing that the City breached a special duty and was liable under a respondent superior theory for a police officer's negligence in shooting Plaintiff. The jury determined that the City was liable under a respondeat superior theory. The City moved for judgment as a matter of law. The district court granted the motion, determining that the City did not owe Plaintiff a special duty. On appeal, the federal circuit court certified a question of law to the Court of Appeals. The Court of Appeals answered that a special duty arises when the police plan and execute a no-knock search warrant at an identified residence, running to the individuals within the targeted premises at the time the warrant is executed. View "Ferreira v. City of Binghamton" on Justia Law

The Court of Appeals reversed the decision of the appellate division modifying and affirming the judgment of Supreme Court declaring that article 14 of the Racing, Pari-Mutuel Wagering and breeding Law violates the constitutional prohibition on gambling to the extent it authorizes interactive fantasy sport (IFS) contests, holding that Plaintiffs did not meet their burden to demonstrate beyond a reasonable doubt that article 14 is unconstitutional.In 2016, the legislature enacted article 14, which authorizes and regulates IFS contests, upon determining that IFS contests are not unconstitutional gambling activities because they are skill-based competitions in which contestants have some influence over the outcome of the fantasy contests. At issue was whether the legislature properly determined that IFS contests authorized in article 14 are not unconstitutional. The Court of Appeals held that the legislature's conclusion that IFS contests are not "gambling" is consistent with precedent delineating the parameters of that term. View "White v. Cuomo" on Justia Law

The Court of Appeals affirmed Defendant's conviction of four counts of assault in the first degree for his participation in an attack involving two victims, holding that Defendant's allegations of error were unavailing.On appeal, the appellate division considered together Defendant's direct appeal from the judgment and his appeal by permission from Supreme Court's order denying his motion to vacate the judgment. The appellate division denied all relief, concluding that Defendant failed to show that he was denied the effective assistance of counsel. On appeal, Defendant argued that his retained attorney's suspension from practice by the United States Court of Appeals, Second Circuit rendered the attorney "constructively suspended" from the practice of law in New York and that, alternatively, his attorney's failure to inform him of of the suspension and pending reciprocal disciplinary proceedings in New York deprived him of his constitutionally-protected right to choice of counsel. The Court of Appeals affirmed, holding that Defendant was not deprived of the attorney of his choice solely due to the imposition of foreign discipline. View "People v. Burgos" on Justia Law