Justia New York Court of Appeals Opinion Summaries

In these joint appeals from putative class actions, the Supreme Court reversed the orders of the Appellate Division rejecting the New York State Department of Labor's (DOL) interpretation of the DOL's Miscellaneous Industries and Occupations Minimum Wage Order (Wage Order), holding that DOL's interpretation of its Wage Order did not conflict with the promulgated language, nor did DOL adopt on irrational or unreasonable construction.Under the Wage Order, an employer must pay its home health care aid employees for each hour of a twenty-four-hour shift. At issue in this case was DOL's interpretation of its Wage Order to require payment for at least thirteen hours of a twenty-four-hour shift if the employee is allowed a sleep break of at least eight hours and actually receives five hours of uninterrupted sleep and three hours of meal break time. Supreme Court refused to adopt DOL's interpretation and determined that class certification was appropriate. The Appellate Division affirmed, concluding that DOL's interpretation was neither rational nor reasonable because it conflicted with the plain language of the Wage Order. The Court of Appeals reversed, holding that the Appellate Division failed to afford adequate deference to DOL's interpretation of the Wage Order. View "Andryeyeva v. New York Health Care, Inc." on Justia Law

The Court of Appeals held that the determination of the New York State Authorities Budget Office (ABO) denying the request of Petitioners - Madison County Industrial Development Agency (MCIDA) and Madison Grant Facilitation Corporation (MGFC) - to file consolidated audit reports was not irrational, arbitrary and capricious, or contrary to law.ABO informed MCFC that it must comply with the reporting requirements of the Public Authorities Accountability Act (PAAA) as a corporation legally affiliated with MCIDA, an industrial development agency (IDA) and a “local authority” subject to the PAAA. MCIDA asked that the ABO treat MGFC as its subsidiary and allow the two entities to file consolidated reports. The ABO denied MCIDA’s request after the Attorney General issued a formal opinion concluding that an IDA is not authorized to create a subsidiary. Petitioners then commenced this N.Y. C.P.L.R. 78 proceeding challenging the ABO’s determination. The Court of Appeals affirmed, holding that the ABO’s narrow record-keeping determination was not contrary to law, nor was it irrational or arbitrary and capricious. View "Madison County Industrial Development Agency v. State Authorities Budget Office" on Justia Law

The Court of Appeals accepted a question certified to it by the federal court of appeals and answered that, pursuant to the Court’s Rule 500.27, if a bond issuer remains obligated to make biannual interest payments until the principal is paid, including after the date of maturity, enforceable claims for such biannual interest do not continue to accrue after a claim for principal of the bonds is time-barred.In 1997, Defendant, the Province of Mendoza, issued bonds valued at $250 million. Plaintiff Moshe Marcel Ajdler was the beneficial owner of $7,050,000 of the principal amount. Plaintiff did not receive any scheduled interest payments or payment of his share of his principal on the maturity date. In 2017, Plaintiff brought this action seeking to collect his share of principal and interest payments to which he was entitled. The district court granted Defendant’s motion to dismiss, concluding that all claims for principal and any accrued interest were time-barred. The Second District concluded that Plaintiff’s claim for principal was untimely but certified questions as to the viability of Plaintiff’s claims to recover interest. The Court of Appeals held that in the absence of a timely action to recover principal, a bondholder cannot enforce the conditional obligation to make post-maturity interest payments. View "Ajdler v. Province of Mendoza" on Justia Law

In this complaint alleging that Defendants were responsible for causing Mason South’s mesothelioma, from which he died, the Court of Appeals affirmed the Appellate Division's decision affirming Supreme Court’s denial of Chevron Corporation’s motion for summary judgment, holding that the record was insufficient to demonstrate the effectiveness of a release South signed when he settled a 1997 lawsuit he filed against Texaco Inc. and other defendants based on his exposure to asbestos.South worked shipboard as a merchant marine for almost forty years. In 1997, South and hundreds of other plaintiffs filed lawsuits against Texaco and other defendants. Texaco reached a settlement with South and other plaintiffs, and South executed a release. Two decades later, South and his wife filed this lawsuit seeking to recover for South’s asbestos-related disease resulting from his asbestos exposure shipboard. In denying Chevron’s motion for summary judgment, Supreme Court determined that the record did not meet Chevron’s heightened burden under the Federal Employers’ Liability Act and admiralty law to demonstrate that the release foreclosed the claims in the instant lawsuit. The Court of Appeals affirmed, holding (1) Chevron had the burden to prove the 1997 release’s viability; and (2) the record was insufficient to demonstrate the effectiveness of the release as a matter of law. View "In re New York City Asbestos Litigation" on Justia Law

The Court of Appeals held that a correctional facility’s release to prosecutors or law enforcement agencies of recordings of nonprivileged telephone calls made by pretrial detainees, who are notified that their calls will be monitored and recorded, does not violate the Fourth Amendment.Defendant was charged with multiple offenses and committed the custody of the New York City Department of Correction. At trial, the prosecution sought to introduce excerpts of four phone calls Defendant made from prison recorded by DOC containing incriminating statements. Supreme Court admitted the recordings into evidence. The Appellate Division affirmed, concluding that the DOC’s failure to notify Defendant that the recordings of his calls may be turned over to prosecutors did not render the calls inadmissible. The Court of Appeals affirmed, holding (1) detainees, who are informed of the monitoring and recording of their calls, have no objectively reasonable constitutional expectation of privacy in the content of those calls; and (2) therefore, a correctional facility does not violate the Fourth Amendment when it records and monitors detainees’ calls and then shares the recordings with law enforcement officials and prosecutors. View "People v. Diaz" on Justia Law

The Court of Appeals affirmed the order of the Appellate Court affirming the judgment of Supreme Court dismissing this action filed by the trustee (Trustee) of three residential mortgage-backed securities (RMBS) alleging violations of representations and warranties regarding the quality of loans contained in the respective securitization trust instruments, holding that the Trustee’s untimely-filed complaint cannot relate back under N.Y. C.P.L.R. 203(f) to a certificate holder’s previously filed action.Defendant served as seller and sponsor of three RMBS securitization trusts, each governed by a separate pooling and servicing agreement. A certificate holder later filed a notice claiming violations of the representations and warranties for each of the trusts. After the limitations period elapsed, the Trustee filed this complaint. Supreme Court dismissed the action with prejudice. The Appellate Division affirmed, concluding that the complaint was time-barred and that the Trustee could not rely on the prior action because the certificate holder lacked standing to sues. The Court of Appeals affirmed, holding that the certificate holder’s action was subject to dismissal, and there was no valid pre-existing action to which a claim in a subsequent amended pleading may relate back. View "U.S. Bank National Ass’n v. DLJ Mortgage Capital, Inc." on Justia Law

The Court of Appeals affirmed the order of the Appellate Division affirming Supreme Court’s dismissal of the complaint filed by the trustee (Trustee) of the ABSHE 2006 residential mortgage-backed securities (RMBS) trust, without prejudice to refiling, holding that N.Y. C.P.L.R. 205(a) applies to an RMBS trustee’s second action when its timely first action is dismissed for failure to comply with a contractual condition precedent.The Trustee first filed an action against Defendant, the sponsor and seller of the trust securitization, and the action was dismissed for failure to comply with a contractual condition precedent, without prejudice to refiling. The Trustee then filed this action against Defendant claiming violations of representations and warranties regarding the quality of the loans contained in the trust. On appeal, Defendant argued that the first action should have been dismissed with prejudice. The Court of Appeals disagreed, holding that the Trustee’s failure to comply with a contractual condition precedent did not foreclose refiling of its action for alleged breach of RMBS representations and warranties pursuant to N.Y. C.P.L.R. 205(a). View "U.S. Bank National Ass’n v DLJ Mortgage Capital, Inc." on Justia Law

The Court of Appeals held that N.Y. Mental Hyg. Law 33.13, which protects the confidentiality of the clinical records of patients and clients as maintained by facilities licensed or operated by the Office of Mental Health or the Office for People with Developmental Disabilities, does not require automatic sealing of the entire court record of all proceedings involving insanity acquittees who have dangerous mental disorders within the meaning of N.Y. Crim. Proc. Law (CPL) 330.20.Defendant, an insanity acquittee, was found to have a dangerous mental disorder as defined by CPL 330.20(1)(c) and was committed to the custody of the Commissioner for the Office for People with Developmental Disabilities. Supreme Court denied Defendant’s motion to seal the entire court record in his case, finding that the documents related to the legal proceedings rather than Defendant’s treatment. The Appellate Division modified. The Court of Appeals affirmed, holding that the legislature provided no automatic sealing requirement of an entire court record in either CPL 330.20 or the Mental Hygiene Law for an insanity acquittee, and Defendant cited no authority for such an obligation. View "In re James Q." on Justia Law

The Court of Appeals held that a resentence on a prior conviction, imposed after the original sentence is vacated as illegal, does not reset the date of sentencing for purposes of determining a defendant’s predicate felony status.Defendant was convicted of attempted robbery in the second degree and was later convicted in another county of attempted robbery in the first degree. In both cases, Defendant was erroneously sentenced as a second felony offender. After he served his sentences, Defendant moved to set aside his sentences. The motions were granted and the courts resentenced Defendant accordingly. Defendant then moved to set aside the sentence on his 1993 conviction, arguing that his 1989 convictions were no longer predicate felonies under the statute governing second felony offender status because he was resentenced on both after the commission of the offense underlying the 1993 conviction. Supreme Court granted the motion, and the Appellate Division affirmed, concluding that Defendant must be resentenced as a first-time offender. The Court of Appeals reversed, holding that the date on which sentence was first imposed upon a prior conviction is the relevant date for purposes of determining when the the sentence upon the prior conviction was imposed for purposes of N.Y. Penal Law 70.06(1)(b)(ii). View "People v. Thomas" on Justia Law

The Court of Appeals reversed the order of the Appellate Division and dismissed this petition and proceeding, holding that Mental Hygiene Legal Service (MHLS) did not have standing to bring this proceeding in its own name to vindicate its clients’ rights under N.Y. Mental Hyg. Law 9.31(b).MHLS, a government entity charged with providing legal services to patients of mental health facilities and hospitals, brought this proceeding in its own name seeking a writ of mandamus to compel a hospital to comply with section 9.31(b), which sets forth the procedure to be followed after a patient requests an admission or retention hearing. The hospital moved to dismiss the petition on the ground the MHLS lacked standing to bring the claim in its own name. Supreme Court denied the hospital’s motion to dismiss and granted the petition, concluding that MHLS had demonstrated a right to mandamus relief. The Appellate Division affirmed. The Court of Appeals reversed and dismissing both the petition and the proceeding, holding that MHLS did not have standing to bring this petition. View "Mental Hygiene Legal Service v. Daniels" on Justia Law