Justia New York Court of Appeals Opinion Summaries

In 2020, Brenda WW, a domestic violence survivor incarcerated for killing her partner, applied for resentencing under the Domestic Violence Survivors Justice Act (DVSJA). Brenda had been convicted of manslaughter, assault, and criminal possession of a weapon, and was serving a 20-year sentence. The County Court denied her application, finding that she did not meet the criteria for resentencing under the DVSJA. The Appellate Division, however, found that Brenda satisfied the statutory criteria and reduced her sentences, noting that she had already served more time than the DVSJA maximum for her convictions. The court also stated that the excess time should be credited toward her postrelease supervision term, effectively leaving her with no postrelease supervision to serve.The County Court initially denied Brenda's application for resentencing, concluding that the abuse she suffered was neither substantial nor a significant contributing factor to her offense, and that her sentence was not unduly harsh. Brenda appealed this decision. The Appellate Division reversed the County Court's decision, granted Brenda's application for resentencing, and reduced her sentences. The Appellate Division imposed maximum periods of postrelease supervision but credited Brenda's excess time served toward this supervision, effectively eliminating it.The New York Court of Appeals reviewed the case and addressed two main issues. First, the court held that the Appellate Division has plenary review power and can make its own factual findings, rejecting the People's argument that the Appellate Division should have reviewed the County Court's decision for abuse of discretion. Second, the court found that the Appellate Division erred in crediting Brenda's excess time served toward her postrelease supervision term. The DVSJA requires resentencing courts to impose a term of postrelease supervision, and excess time spent incarcerated cannot be credited toward that term. The Court of Appeals remitted the case to the Appellate Division to determine the appropriate period of postrelease supervision. View "People v Brenda WW" on Justia Law

The defendant was charged with first-degree manslaughter after fatally stabbing her boyfriend during a violent altercation. She claimed that she acted in self-defense, citing a history of severe physical abuse by the victim, including multiple incidents of strangulation and a recent sexual assault immediately preceding the stabbing. Several witnesses corroborated the defendant’s account of ongoing abuse, and an order of protection had previously been issued against the victim.The case was tried in Supreme Court, Erie County, where the defendant’s counsel pursued a justification defense under Penal Law § 35.15. During summation, the prosecutor misrepresented the defendant’s testimony by stating that she had never claimed to fear for her life, despite clear testimony to the contrary. The prosecutor also repeatedly accused the defendant of lying, using the term “lies” numerous times. Defense counsel did not object to these remarks. The jury convicted the defendant. On appeal, the Appellate Division, Fourth Department, affirmed the conviction, holding that the issue was unpreserved and that counsel’s failure to object did not constitute ineffective assistance. However, the Appellate Division did grant sentencing relief under the Domestic Violence Survivors Justice Act.The New York Court of Appeals reviewed the case and held that the defendant was denied meaningful representation due to her counsel’s failure to object to the prosecutor’s improper summation remarks. The Court found that the prosecutor’s misstatement of the evidence and repeated personal attacks on the defendant’s credibility exceeded permissible advocacy and undermined the fairness of the trial. The Court concluded that, in the absence of any strategic justification for counsel’s silence, the defendant was deprived of a fair trial. The order of the Appellate Division was reversed, and a new trial was ordered. View "People v T.P." on Justia Law

The defendant was convicted of second-degree murder for the fatal stabbing of a 20-year-old in August 2007, when he was 16 years old. The prosecution presented police-arranged single photo identifications made the day after the crime. The defendant moved to suppress these identifications, arguing they were conducted in a suggestive manner. The Supreme Court ordered a Rodriguez/Wade hearing to determine the admissibility of the identifications, but the hearing was never held. During the trial, the prosecution called an eyewitness who identified the defendant as the perpetrator, despite earlier stating they would not call this witness. The defense counsel did not object to the witness being called or request a Rodriguez/Wade hearing.The Supreme Court convicted the defendant, and he appealed, arguing that the missing transcript of jury deliberation proceedings constituted a mode of proceedings error and that his trial counsel was ineffective. The Supreme Court summarily denied the defendant's CPL 440.10 motion without an evidentiary hearing and denied his motion for a reconstruction hearing. The Appellate Division modified the judgment by reducing the defendant's sentence but affirmed the order denying the CPL 440.10 motion, rejecting the defendant's claims.The New York Court of Appeals reviewed the case and rejected the defendant's mode of proceedings claim, holding that a missing transcript alone does not entitle a defendant to vacatur of their conviction. The court stated that the proper remedy for a missing transcript is a reconstruction hearing, provided the defendant's conduct shows a good faith effort to obtain prompt and effective reconstruction. The court also held that the Supreme Court abused its discretion by summarily denying the CPL 440.10 motion without an evidentiary hearing, as the defendant's ineffective assistance claim could not be resolved without resolving questions of fact. The case was remitted to the Supreme Court for an evidentiary hearing on the CPL 440.10 motion. View "People v Salas" on Justia Law

The case involves a dispute over whether certain information about deceased individuals, retained and indexed by the New York State Department of Health (DOH), should be disclosed under the Freedom of Information Law (FOIL). The DOH already publishes an online database with limited information for deaths from 1957 to 1972. The petitioner, Reclaim the Records, requested disclosure of the same categories of information and any additional indexed information for deaths from all available years through 2017.The Supreme Court granted the petition and ordered DOH to disclose the records, with social security numbers redacted. The Appellate Division reversed and dismissed the petition, concluding that the additional fields of information for deaths from 1957 to 1972, and all information from 1973 to 2017, were exempt from disclosure under Public Health Law § 4174 (1) (a) and that disclosure would constitute an unwarranted invasion of personal privacy.The New York Court of Appeals reviewed the case and concluded that DOH must disclose the same categories of information it already publishes online for deaths from 1957 to 1972 for all years through 2017. The court held that DOH had not shown that any exemption applies to these categories of information. However, the court also held that disclosure of a decedent's medical history, cause of death, location of interment, and whether they were buried, cremated, or made an anatomical gift would constitute an unwarranted invasion of personal privacy and is therefore exempt from disclosure under FOIL. The court remitted the matter to the Supreme Court to determine whether DOH must disclose additional portions of its death indices containing other fields of information not addressed in the decision. View "Matter of Reclaim the Records v New York State Dept. of Health" on Justia Law

In 2019, New York City enacted Local Law No. 97, requiring significant reductions in greenhouse gas emissions from large buildings, aiming for a 40% reduction by 2030 and an 80% reduction by 2050, relative to 2005 levels. Shortly after, New York State passed the Climate Leadership and Community Protection Act (Climate Act), targeting a 100% reduction in greenhouse gas emissions from 1990 levels by 2050, with an interim goal of a 40% reduction by 2030. The Climate Act tasked the Department of Environmental Conservation (DEC) with setting statewide emissions limits and established a Climate Action Council to develop a Scoping Plan for achieving these targets.Plaintiffs, representing residential buildings subject to Local Law No. 97, filed a declaratory judgment action claiming the local law was preempted by the Climate Act. The defendants, including the City of New York and its Department of Buildings, moved to dismiss the complaint. The Supreme Court granted the motion, dismissing the complaint entirely. However, the Appellate Division modified this decision, denying the motion regarding the preemption claim and affirming the rest. The Appellate Division held that the defendants failed to demonstrate that the Climate Act did not preempt Local Law No. 97.The New York Court of Appeals reviewed the case and reversed the Appellate Division's decision. The Court held that the Climate Act does not preempt the field of regulating greenhouse gas emissions. The Court emphasized that the Climate Act's legislative findings and savings clause indicate an intent to allow complementary local regulations. The Court concluded that the State did not express or imply an intent to preempt local efforts to reduce greenhouse gas emissions, and thus, Local Law No. 97 is not preempted by the Climate Act. The certified question was answered in the negative, and the defendants' motion to dismiss was granted. View "Glen Oaks Vil. Owners, Inc. v City of New York" on Justia Law

The defendant was arrested after his sister-in-law reported to the police that he had raped her while her young child watched. The victim testified that she lived in an upstairs apartment with her family, while the defendant lived downstairs. On May 25, 2017, the defendant entered the victim's room under the pretense of delivering mail and propositioned her for sex, and when she refused, he became aggressive, eventually raping her. The victim's child sought help, leading to the defendant's arrest.The defendant was charged with first-degree rape, first-degree sexual abuse, and third-degree rape. Before the trial, the prosecution sought to introduce evidence that the defendant had previously attempted to rape two other sisters-in-law. The trial court allowed this evidence, instructing the jury that it could be considered for purposes other than proving the defendant's propensity to commit the crime. The defendant argued that the sexual encounter was consensual, suggesting an affair and rough consensual sex. The jury convicted the defendant on all counts. The Appellate Division affirmed the conviction, with one Justice dissenting, stating that the evidence was relevant to establish the defendant's use of force and provide background information on the family dynamics.The New York Court of Appeals reviewed the case and held that the trial court did not err in admitting the evidence of prior assaults. The Court explained that the evidence was relevant to refute the defendant's claim of consensual sex and to establish his intent to rape the victim. The Court also found that the evidence provided necessary background information on the family dynamics and the defendant's relationship with the victim. The Court concluded that the probative value of the evidence outweighed its potential prejudice and affirmed the order of the Appellate Division. View "People v. Sin" on Justia Law

Ali Tuckett sought damages from the State of New York under Court of Claims Act § 8-b, claiming unjust conviction and imprisonment. Tuckett's 2011 conviction for sexually abusing his minor cousin, N.M., was vacated after N.M. recanted his testimony in 2013, admitting he had lied. Tuckett then filed a claim for damages, asserting his innocence and that he did not cause his conviction.The Court of Claims dismissed Tuckett's claim, concluding he did not prove his innocence by clear and convincing evidence. The court excluded polygraph evidence Tuckett wanted to present and found N.M.'s recantation not credible, relying on testimony from the original investigation and trial. The Appellate Division affirmed the dismissal, agreeing that any reliance on hearsay was harmless and that the court's findings were supported by the record. Two justices dissented, believing the court improperly relied on evidence outside the record and hearsay.The New York Court of Appeals reviewed the case and affirmed the Appellate Division's decision. The court found that any potential hearsay error was harmless given the substantial non-hearsay evidence supporting the Court of Claims' decision. The court also determined that the findings of fact were supported by the record and that the Court of Claims did not improperly rely on evidence outside the record. Additionally, the court rejected Tuckett's argument that the Court of Claims applied an incorrect presumption regarding the reliability of recantation testimony, noting that the court provided specific reasons for finding N.M.'s recantation not credible.The Court of Appeals held that Tuckett failed to prove his innocence by clear and convincing evidence and affirmed the dismissal of his claim. View "Tuckett v State of New York" on Justia Law

The defendant, Laquawn Lewis, was charged with attempted murder, robbery, assault, and obstruction of governmental administration. Leading up to his trial, Lewis expressed dissatisfaction with his appointed counsel and filed various pro se motions. He eventually requested to represent himself, stating his intention to proceed pro se. The court denied his request without conducting the required inquiry into whether his decision was knowing, voluntary, and intelligent.At trial, Lewis reiterated his desire to represent himself, but the court again denied his request and proceeded with jury selection. Lewis later pleaded guilty to avoid a potential life sentence based on an incorrect assumption about his status as a persistent felony offender. After realizing the error, defense counsel moved to withdraw the guilty plea, which the court granted. Lewis renewed his request to represent himself, but the court deferred the decision until the trial date and ultimately denied it again. Lewis was convicted of all charges except attempted murder and sentenced to 25 years' incarceration and 5 years' post-release supervision.The Appellate Division affirmed the judgment, holding that Lewis's requests to proceed pro se were not unequivocal and that his legal sufficiency argument was unpreserved and without merit. A Judge of the Court of Appeals granted Lewis leave to appeal.The New York Court of Appeals concluded that the trial court violated Lewis's constitutional right to self-representation by denying his unequivocal request to proceed pro se without the requisite inquiry. The court held that Lewis's request was clear and timely, and the trial court's failure to conduct an inquiry warranted a new trial. The court also found that Lewis's legal sufficiency argument was unpreserved. Consequently, the Court of Appeals reversed the Appellate Division's order and granted Lewis a new trial. View "People v Lewis" on Justia Law

In 2018, the Westchester County Department of Social Services (DSS) initiated neglect proceedings against a mother for leaving her young children unsupervised. The mother consented to a neglect finding, and subsequent permanency hearings were held regarding the placement of two of her children in DSS custody. In 2020, the Family Court trial discharged the children to the mother's custody, but later returned them to DSS after allegations of the mother's non-compliance and further neglect surfaced. In March 2022, the Family Court continued the children's placement with DSS and ordered the mother to participate in various programs and evaluations. The mother appealed this order.During the appeal, another permanency hearing was held, resulting in an October 2022 order that also continued the children's placement with DSS and reiterated the requirements for the mother. The mother appealed this order as well. While these appeals were pending, new permanency hearings and orders were issued, superseding the previous ones. The Appellate Division dismissed the mother's appeals as moot, given that the orders had expired and been replaced.The New York Court of Appeals reviewed the case and affirmed the Appellate Division's decision. The Court held that the appeals were moot because the orders in question had been superseded by subsequent orders, and thus no longer affected the mother's rights. The Court also determined that the Appellate Division did not abuse its discretion in declining to invoke the mootness exception, as the issues raised were not sufficiently substantial or novel. Additionally, the Court declined to adopt a blanket mootness exception for all permanency hearing orders, emphasizing that such a rule would be impractical and could undermine the purpose of timely and effective judicial review in child welfare cases. View "Matter of Joshua J." on Justia Law

Ezrasons, Inc., a New York corporation and beneficial owner of Barclays PLC shares, initiated a derivative action on behalf of Barclays against several current and former Barclays directors and officers, as well as Barclays Capital Inc. (BCI). The complaint alleged breaches of fiduciary duties under English law, causing significant harm to Barclays. Defendants moved to dismiss the complaint, arguing that under English law, only registered members of Barclays could maintain such an action, and Ezrasons was not a registered member.The Supreme Court granted the motion to dismiss, holding that the internal affairs doctrine required the application of English law, which precluded Ezrasons from having standing. The court rejected the argument that New York's Business Corporation Law (BCL) sections 626 (a) and 1319 (a) (2) overrode the internal affairs doctrine. The Appellate Division affirmed, agreeing that the internal affairs doctrine applied and that Ezrasons lacked standing under English law.The New York Court of Appeals reviewed the case and affirmed the Appellate Division's decision. The court held that the internal affairs doctrine, which mandates that the substantive law of the place of incorporation governs disputes related to corporate internal affairs, was not overridden by BCL sections 626 (a) and 1319 (a) (2). The court found no clear legislative intent to displace the doctrine and concluded that Ezrasons lacked standing under English law to maintain the derivative action. The order of the Appellate Division was affirmed, with costs. View "Ezrasons, Inc. v Rudd" on Justia Law