Justia New York Court of Appeals Opinion Summaries

In this case, the defendant was accused of sexually assaulting three minors between 2007 and 2009. The police obtained a search warrant and found child pornography on the defendant's computers, including an encrypted file they could not access. The defendant was indicted on multiple counts, including sexual conduct against a child and possession of child pornography. He posted bail and was released but was later remanded to jail for allegedly posting a blog that intimidated a witness.The trial court assigned counsel and experts to assist the defendant, who later chose to represent himself. During the trial, the defendant's daughter testified about a recorded conversation in which one of the victims allegedly recanted her accusations. The prosecution used recorded jail phone calls to challenge the daughter's testimony, revealing that the defendant had discussed trial strategies with her. The jury found the defendant guilty of one count of sexual conduct against a child and all child pornography counts but deadlocked on other charges. The defendant entered an Alford plea to the deadlocked counts.The Appellate Division affirmed the judgment, and the New York Court of Appeals reviewed the case. The primary issue was whether the defendant's right to present a defense was violated by the prosecution's monitoring of his jail phone calls. The Court of Appeals held that the defendant's right to present a defense was not violated. The court noted that the defendant had ample time to prepare his defense while out on bail and had other means to communicate with witnesses. The court also found that the defendant's request to proceed pro se was unequivocal and that the trial court had conducted a proper inquiry into the risks of self-representation. The order of the Appellate Division was affirmed. View "People v Dixon" on Justia Law

Anthony Blue was convicted of five counts of second-degree burglary. He argued that his waiver of the right to counsel was invalid because the trial judge did not inform him of his maximum sentencing exposure. Blue also contended that his indictment should have been dismissed on statutory speedy-trial grounds, asserting that the time between his indictment and arraignment should not be excluded from the speedy-trial calculation.The Supreme Court denied Blue's motion to dismiss the indictment, finding that the time between his co-defendant's request for an adjournment and Blue's arraignment was excludable under CPL 30.30 (4) (d). The court also determined that Blue's waiver of counsel was knowing, voluntary, and intelligent, despite not being informed of the maximum sentencing exposure in years. The Appellate Division affirmed these decisions, concluding that the 57 days between the co-defendant's adjournment request and Blue's arraignment were properly excluded from the speedy-trial calculation.The New York Court of Appeals reviewed the case and affirmed the Appellate Division's order. The court held that a defendant can be joined for trial with a co-defendant at the time of indictment, and the exclusion under CPL 30.30 (4) (d) applies to pre-arraignment time. The court also found that Blue's waiver of counsel was valid, as he was adequately warned of the dangers of self-representation and understood the potential sentencing exposure. The court concluded that the 57-day period was excludable, leaving the speedy-trial clock at 180 days, within the statutory limit. Blue's remaining challenges were deemed unpreserved or meritless. View "People v Blue" on Justia Law

The defendant was charged with unlawfully possessing a defaced firearm and unlawfully possessing a loaded firearm outside of his home or place of business. Before the trial, the prosecution filed a Sandoval application to cross-examine the defendant about his prior convictions and pending cases. The trial court held an in-camera conference on this motion without the defendant present. Later, in the defendant's presence, the court announced its decision on the Sandoval application without hearing arguments on the merits or confirming the defendant's understanding.The case proceeded to a bench trial where the prosecution presented evidence, including testimony from an arresting officer and surveillance footage. The trial court found the defendant guilty on both counts and sentenced him to imprisonment and post-release supervision. The Appellate Division affirmed the conviction, with one Justice dissenting on the grounds that the defendant was denied his right to be present during the Sandoval application consideration. The dissenting Justice granted the defendant leave to appeal.The New York Court of Appeals reviewed the case and held that the defendant's right to be present during a material stage of his prosecution was violated. The court found that the defendant had a right to be present at the initial in-chambers conference on the Sandoval application and that the subsequent in-court proceeding did not cure this violation. The court emphasized that the defendant's presence is crucial for meaningful participation in such hearings. Consequently, the Court of Appeals reversed the Appellate Division's order and granted the defendant a new trial. View "People v Sharp" on Justia Law

On a snowy day in December 2018, the Superintendent of Highways for the Town of Carmel, Michael J. Simone, drove into an intersection without the right of way and collided with Ana Orellana's vehicle. Simone had been inspecting road conditions during a snowstorm and had directed his team to salt the roads. After completing his inspection, he was returning to his office when the accident occurred. Simone testified that he was not in a rush, did not consider the situation an emergency, and had no intention of conducting further inspections en route.The Supreme Court granted the defendants' motion for summary judgment, holding that Simone's conduct was protected under Vehicle and Traffic Law § 1103 (b), which exempts municipal employees from liability for ordinary negligence when "actually engaged in work on a highway." The court denied the plaintiff's cross-motion for summary judgment as academic. The Appellate Division affirmed this decision.The New York Court of Appeals reviewed the case and reversed the lower courts' decisions. The Court held that Simone was not "actually engaged in work on a highway" at the time of the accident, as he had completed his inspection and was merely returning to his office. Therefore, the protections of Vehicle and Traffic Law § 1103 (b) did not apply. The Court granted the plaintiff's cross-motion for summary judgment on the issue of liability and denied the defendants' motion for summary judgment. View "Orellana v Town of Carmel" on Justia Law

The case involves two defendants, Matthew Corr and Bryan McDonald, who were convicted of sex offenses in other states and were required to register as sex offenders under the laws of those states. After relocating to New York, they were required to register as level-one risk under the Sex Offender Registration Act (SORA). Both defendants requested that the Supreme Court order them registered nunc pro tunc to the date when they registered as sex offenders in the state where they were convicted, effectively giving them credit for the time registered in the foreign jurisdiction against the 20-year registration period.The Supreme Court denied their requests, and the Appellate Division affirmed the decisions. The defendants argued that the phrase "initial date of registration" in SORA refers to the date they initially registered in the state of conviction, not the date of subsequent registration in New York. The People countered that SORA's use of the phrase "initial date of registration" refers to the date when an offender first registers under SORA.The Court of Appeals of New York held that the phrase "initial date of registration" refers to the date when an offender first registers under SORA, not the date an offender is required to register under the laws of another jurisdiction. The court found that the defendants' interpretation of the statute would award sex offenders credit for time spent registered under the laws of another state, which is not provided for in SORA. The court affirmed the decisions of the lower courts, ruling that the defendants were not entitled to credit for their time registered as sex offenders under the laws of other states. View "People v Corr" on Justia Law

The plaintiff, K.E. Liggett, is a tenant in a Manhattan apartment building owned by the defendant, Lew Realty LLC. Liggett filed a lawsuit when Lew Realty attempted to increase her rent in 2021, arguing that her apartment is rent-stabilized and she is entitled to a rent-stabilized lease, overcharges, and attorney's fees. Liggett's claim is based on a stipulation from 2000 between Lew Realty and a previous tenant, Edward McKinney, which required McKinney to waive his right to file a Fair Market Rent Appeal (FMRA). Liggett argues that this stipulation is void as it goes against public policy, and because it led to the deregulation of the apartment, the deregulation is invalid and the apartment remains rent-stabilized.The Supreme Court initially denied Lew Realty's motion to dismiss, agreeing with Liggett that the stipulation is unenforceable as it waives the protections of the rent laws. However, the Appellate Division reversed this decision and dismissed the complaint. The Appellate Division concluded that the protection against waiving the benefits of rent control law did not apply to McKinney as he was not an established tenant when he signed the stipulation. The Appellate Division also concluded that Liggett's claim was akin to an FMRA and therefore barred by the statute of limitations.The Court of Appeals reversed the decision of the Appellate Division. The court held that the stipulation is void as it waives a benefit of the rent laws, regardless of McKinney's status as a tenant. The court also held that the statute of limitations does not bar Liggett's claim that the apartment is subject to rent stabilization. The court remanded the case, allowing Lew Realty to establish other reasons for why the apartment was not rent-stabilized when Liggett took tenancy. The court did not address any issues related to Liggett's rent overcharge claims. View "Liggett v Lew Realty LLC" on Justia Law

The case involves a group of petitioners, including parents with children in nonpublic schools, who sought to compel a local school district to transport children to their private schools on days when the public schools were closed. The petitioners requested that the Washingtonville Central School District provide transportation for children attending nonpublic schools on 20 days when public schools were closed. The District denied these requests, citing its policy that it is not required to provide transportation to nonpublic schools on days when the District's schools are not in session. This policy aligns with guidance published by the State Education Department. The petitioners then initiated a hybrid CPLR article 78 proceeding and declaratory judgment action, seeking a declaration that the District must transport students to nonpublic schools on all days those schools are open and that the State Education Department's contrary guidance is invalid.The Supreme Court ruled in favor of the petitioners, concluding that the language of Education Law § 3635 (1) (a) required the District to transport nonpublic school students on all days their schools were open. The court granted the petitioners' motion for summary judgment on their request for declaratory relief, issued a permanent injunction, and denied the State Education Department's cross motion for summary judgment. However, the Appellate Division reversed this decision, finding that the language in Education Law § 3635 (1) (a) was ambiguous. After reviewing the provision's legislative history, the Appellate Division held that the law "permits, but does not require, school districts outside New York City to transport nonpublic school students to and from school on days when the public schools are closed."The Court of Appeals of New York affirmed the decision of the Appellate Division. The court held that Education Law § 3635 (1) (a) does not require school districts to provide transportation to nonpublic schools on days when public schools are closed. The court found that the phrase "sufficient transportation facilities" in the statute is ambiguous and could be interpreted in various ways. After examining the legislative history of the statute, the court concluded that the Legislature did not intend to require school districts to provide transportation to nonpublic schools on days when public schools are closed. The court also rejected the petitioners' arguments that the District's policy and the State Education Department's interpretation of Education Law § 3635 (1) (a) denied nonpublic school students equal protection of the law and that the State Education Department exceeded its statutory authority under Education Law § 3635 (1) (a). View "Matter of United Jewish Community of Blooming Grove, Inc. v Washingtonville Cent. Sch. Dist." on Justia Law

The case revolves around a dispute between MAK Technology Holdings Inc. (plaintiff) and Anyvision Interactive Technologies Ltd. (defendant). The defendant, an Israeli company selling facial-recognition software, engaged the plaintiff in 2017 to arrange introductions with potential customers in exchange for referral payments based on revenues generated from any resulting product-license agreements. The parties formalized their agreement in a written Referral Agreement with a defined "Effective Date" of November 23, 2017, and a term of three years. The agreement was amended twice in 2018 to include a compensation arrangement for equity investments in the defendant, separate from their arrangement with respect to product licenses.The plaintiff initiated a lawsuit to recover compensation allegedly owed under the amended Referral Agreement, claiming that a nonparty made an investment in the defendant in July 2021 for which the plaintiff is owed a $1.25 million fee under the Second Amendment. The defendant moved to dismiss this claim on the ground that the transaction occurred eight months after the Term of the Referral Agreement expired in November 2020. The Supreme Court denied the motion, and a divided Appellate Division affirmed, both concluding that the error-infected language in section 2 of the Second Amendment creates an ambiguity with respect to the length of the Term.The Court of Appeals of New York disagreed with the lower courts' decisions. The court held that the plaintiff is not entitled to a $1.25 million fee for a transaction consummated eight months after the "Term" of the parties' agreement expired. The court found that minor syntactic and spelling errors in the preamble of an amendment to the contract cannot reasonably be read as modifying the length of the Term. The court also rejected the plaintiff's argument that the amendment is a separate agreement with a distinct term. Therefore, the court reversed the order of the Appellate Division, granted the defendant's motion to dismiss the first cause of action for breach of contract to the extent based on the July 2021 transaction, and answered the certified question in the negative. View "MAK Tech. Holdings Inc. v Anyvision Interactive Tech. Ltd." on Justia Law

The case revolves around a defendant who was charged with attempted second-degree murder, second-degree assault, and other charges. The defendant threatened his children with a knife and stabbed his pregnant wife multiple times. In 2019, the defendant was indicted, and the prosecution declared readiness for trial. However, on January 1, 2020, amendments to New York's discovery and statutory speedy trial rules went into effect. On the first day of trial, the defendant moved to dismiss the indictment on statutory speedy trial grounds, arguing that the prosecution had become unready for trial when the amendments came into effect and had failed to file a certificate of compliance with the new discovery rules.The Supreme Court denied the motion, holding that the amendments do not apply to cases arraigned before January 1, 2020. The jury acquitted the defendant of attempted second-degree murder but convicted him of the remaining counts. The Appellate Division, however, reversed the judgment, granted the defendant's motion, and dismissed the indictment. The Appellate Division held that the prosecution was placed in a state of unreadiness on January 1, 2020, and were required to file a certificate of compliance to become ready thereafter.The Court of Appeals reversed the Appellate Division order. The court held that the amendments did not vitiate the prosecution's prior readiness statement. The court found that the amendments specifically tie the certificate of compliance requirement to the prosecution's ability to state ready and be deemed ready. Because the legislature established the certificate of compliance requirement as a condition precedent to declaring ready for trial and did not indicate an intent to undo the prosecution's prior readiness statements, there is no basis to apply that requirement prospectively to a case where the prosecution was in a trial-ready posture when it went into effect. Therefore, the prosecution is not chargeable for any delay after January 1, 2020, and thus remained within the applicable 181-day statutory speedy trial limit. View "People v King" on Justia Law

On March 26, 2017, two men robbed a restaurant in Queens. One of the robbers, a Black man wearing a red hoodie, black jacket, and a bandana over his face, approached the Assistant Manager, Sumintra Ramsahoye, and demanded she open the safe. When she couldn't, she handed over the contents of the cash register drawers. Meanwhile, the other perpetrator stood next to another employee, Jordan Guzman. After the robbers fled, Guzman called the police. Police Officer Bryce Blake and his partner arrived at the restaurant within minutes and observed the defendant, Freddie T. Wright, standing in the parking lot dressed in a black jacket and red hoodie. Wright fled upon seeing the patrol car, but was eventually arrested. Guzman and Ramsahoye were brought to the house where Wright was arrested to identify him.Wright moved to suppress the identification testimony, arguing that the identification procedures were unduly suggestive. The court denied the motion, finding that the identifications were not "overly suggestive and improper" because they were made in a "very short spatial and temporal time between the incident and arrest." During jury selection, Wright raised a Batson challenge to the People's use of peremptory strikes on two prospective jurors—C.C. and K.C. The court found that the reasons proffered by the People for their strike of C.C. and K.C. were not pretextual. Wright was ultimately convicted of second-degree robbery and second-degree criminal trespass.The Appellate Division affirmed the conviction, holding that Wright had "failed to satisfy his burden of demonstrating, under the third prong of the Batson test, that the facially race-neutral explanation given by the prosecutor was a pretext for racial discrimination." The Court of Appeals granted Wright leave to appeal.The Court of Appeals affirmed the lower courts' decisions. The court found that there was record support for the determinations that the People had valid, race-neutral reasons for striking the two prospective jurors. The court also found record support for the conclusions of the courts below that the show-up procedure used by police was not unduly suggestive. The court concluded that the order of the Appellate Division should be affirmed. View "People v Wright" on Justia Law