Justia New York Court of Appeals Opinion Summaries

The defendant, Kevin L. Thomas, was on lifetime parole for prior narcotics offenses. An off-duty police officer, familiar with Thomas, observed him driving outside his county of residence, which was a violation of his parole conditions. The officer contacted an on-duty officer who initiated a traffic stop after observing Thomas commit a traffic infraction. During the stop, Thomas provided inconsistent responses and refused to consent to a search of his vehicle. The police contacted Thomas's parole officer, who arrived at the scene and conducted a warrantless search of Thomas's vehicle, discovering a large quantity of heroin.The County Court denied Thomas's motion to suppress the evidence, finding that the initial stop was justified and that the police had a founded suspicion of criminality justifying the continued detention of Thomas to contact his parole officer. The court also found that the parole officer's search was rationally and reasonably related to his parole duties. Thomas was convicted of criminal possession of a controlled substance in the third degree. The Appellate Division affirmed the decision, with two Justices dissenting, arguing that Thomas was detained beyond what was reasonable under the circumstances.The Court of Appeals reversed the decision, stating that the lower courts applied an incorrect legal standard in analyzing whether the traffic stop was unreasonably prolonged. The court held that the proper standard for detaining an individual beyond the time reasonably required to complete a traffic stop is reasonable suspicion. The court found that the traffic stop was justified at its inception, but the courts below evaluated whether the traffic stop was prolonged beyond the time reasonably required for its completion under the founded suspicion standard, a lesser standard than the reasonable suspicion necessary to prolong a traffic stop. The case was remitted to the County Court for further proceedings under the correct standard. View "People v Thomas" on Justia Law

In October 2016, 65-year-old David Pena was assaulted by a stranger on the street. Pena, who did not see his attacker's face during the assault, later identified Mark Watkins as the assailant. Watkins was subsequently convicted of assault in the first degree, assault in the second degree, and criminal possession of a weapon in the third degree. The only identification evidence presented at trial was Pena's testimony, who identified Watkins as his attacker and the person depicted in surveillance footage of the attack. The surveillance video, however, was too blurry to clearly depict the assailant's face.Watkins appealed his conviction, arguing that his trial counsel was ineffective for failing to request a cross-racial identification instruction. The Appellate Division affirmed the conviction, holding that Watkins' ineffective assistance of counsel claim was unreviewable on direct appeal because it involved matters not fully explained by the record. The panel also concluded that Watkins received effective assistance under the state and federal standards because he had not shown that it was objectively unreasonable for counsel to refrain from requesting a jury charge on cross-racial identification.The Court of Appeals of New York affirmed the lower court's decision. The court held that at the time of Watkins' trial in July 2017, there was no clear entitlement to a cross-racial identification charge. The court noted that while a cross-racial identification charge had been recommended by both the American Bar Association and the New York State Justice Task Force, the court's precedent had long vested the trial court with discretion over the content of an eyewitness identification charge. Therefore, the court concluded that the decision to forgo a request for the cross-racial identification charge was not the kind of "egregious" single error that rises to the level of ineffective assistance. View "People v Watkins" on Justia Law

The case revolves around a dispute concerning a 2018 merger between FanDuel Ltd. and the U.S. assets of nonparty Paddy Power Betfair plc. The plaintiffs, founders and shareholders of FanDuel, alleged that the defendants, including FanDuel's board of directors and certain shareholders, deliberately undervalued FanDuel's assets during the merger negotiations, resulting in the preferred shareholders receiving all the benefits of the merger while the common shareholders received nothing. The plaintiffs claimed that the defendants breached their fiduciary duties by failing to obtain a fair valuation of the merger consideration and by promoting their own interests at the expense of the common shareholders.The Supreme Court of New York County partially granted and partially denied the defendants' motions to dismiss the complaint. The court held that New York law applied to the plaintiffs' claims because the internal affairs doctrine was inapplicable where the defendants were not current officers, directors, and shareholders at the time of the lawsuit. The court further held that the plaintiffs adequately stated their claims for breach of fiduciary duty under New York law.The Appellate Division reversed the order of the Supreme Court, holding that Scots law applied to the plaintiffs' claims under the internal affairs doctrine. The court stated that the directors of a company generally owe duties only to the company as a whole rather than to the shareholders, except in special factual circumstances not present in this case. Therefore, the court concluded that the plaintiffs failed to state a claim for breach of fiduciary duty under Scots law.The Court of Appeals of New York reversed the order of the Appellate Division, holding that while Scots law applied to the plaintiffs' claims, the plaintiffs' allegations could give rise to a possible inference that special circumstances were present, which could give rise to a cognizable fiduciary duty claim under Scots law. Therefore, the court held that the Appellate Division erroneously granted the defendants' motions to dismiss the first, second, and fourth causes of action. View "Eccles v Shamrock Capital Advisors, LLC" on Justia Law

Michele Rawlins, a former school principal and member of the Teachers' Retirement System of the City of New York (TRS), was diagnosed with post-traumatic stress disorder (PTSD) following a series of incidents involving a disgruntled food-service worker. The worker's behavior left Rawlins feeling threatened and harassed, leading to her inability to perform her job responsibilities. The final incident occurred in April 2019, when the worker, who had been transferred to another location, entered the school and demanded to speak with Rawlins, insisting she had his "belt and wallet." Rawlins interpreted the worker's remarks as having "sexual overtones" and felt she was being stalked. She left the school building and never returned to work following the incident.Rawlins applied for accidental disability retirement benefits (ADR) from the TRS, but her application was denied. The TRS Medical Board determined that she did not sustain an accident in the work setting and that "purposeful conduct by coworkers giving rise to a disabling injury is not an accident within the meaning of the pension statute." Rawlins reapplied for ADR, but the Board maintained its previous determination. Rawlins then commenced a CPLR article 78 proceeding to annul the Board's determination. The Supreme Court denied the petition and dismissed the proceeding, stating that the Board's determination had a rational basis. The Appellate Division affirmed the Supreme Court's decision, and Rawlins was granted leave to appeal.The Court of Appeals affirmed the lower courts' decisions. The court held that substantial evidence supported the Board's determination that Rawlins' injury was not caused by an "accident" within the meaning of the statutory scheme. The court declined to adopt a rule that "purposeful conduct by coworkers" can never be the basis for an award of ADR. Instead, the court stated that when a member's disability is alleged to have resulted from the intentional acts of any third party, the relevant question continues to be whether the injury-causing event was sudden, unexpected, and outside the risks inherent in the work performed. View "Matter of Rawlins v Teachers' Retirement Sys. of the City of N.Y." on Justia Law

The defendant, Dwane Estwick, was convicted of first-degree and second-degree robbery following a jury trial and was sentenced to 12 years in prison, followed by five years of post-release supervision. The defendant claimed that the prosecution failed to provide a race-neutral explanation for its peremptory strike of a prospective juror, K.S., an African-American female. The defendant argued that this failure constituted a violation of the Batson framework, which prohibits racial discrimination in jury selection, and thus, he was entitled to a new trial.The Appellate Division affirmed the conviction (208 AD3d 799 [2d Dept 2022]). A Judge of the Court of Appeals granted leave to appeal (39 NY3d 1078 [2023]). The defendant reiterated his claim that the prosecution failed to provide a race-neutral explanation for its peremptory strike of K.S., thus violating the Batson framework.The Court of Appeals of New York agreed with the defendant. It found that the defendant had established a prima facie case of discrimination regarding the prosecution's peremptory challenge against K.S. The burden then shifted to the prosecution to provide a race-neutral basis for its peremptory strike, which it failed to do. Instead, the trial court stepped in to provide an explanation, speculating that the prosecution had gotten a "bad vibe" from K.S. The court ruled that the prosecution had "given a legitimate race-neutral reason" for the strike. The Court of Appeals held that this was a serious departure from the Batson framework and constituted an error of the highest order. The court's speculation as to the prosecution's basis for the strike was irrelevant and deprived the defendant of any meaningful way to demonstrate pretext in the face of the prosecution's silence. As a result, the Court of Appeals reversed the Appellate Division order and ordered a new trial. View "People v Estwick" on Justia Law

The case revolves around a parolee, Eugene L. Lively, who was searched by parole officers during a home visit in February 2021. The officers were looking for a parole absconder they believed might be at Lively's residence. During the search, an officer found a small case used for headphones in Lively's pocket, which contained heroin. Lively was subsequently charged with one count of criminal possession of a controlled substance in the third degree.Lively moved to suppress the physical evidence obtained from him. The suppression court denied his motion, ruling that the search was lawful as the parole officers were performing their duties. Lively was convicted of third-degree criminal possession of a controlled substance after a bench trial. On appeal, the Appellate Division affirmed the judgment in a split decision. The majority held that the search was substantially related to the parole officers' duties. Two dissenting justices argued that the search was unlawful as there was no evidence that it was related to Lively's status as a parolee or that he had violated his parole conditions.The Court of Appeals reversed the lower courts' decisions. The court held that the People failed to establish at the suppression hearing that the search of Lively's pocket was substantially related to the parole officers' duties. The court found that the People did not provide evidence that Lively was aware of the absconder's parole status, that he was harboring an absconder, or that he was violating his parole conditions. The court concluded that the search of Lively's pocket was not substantially related to the parole officers' duties under the circumstances, and thus, the evidence obtained should have been suppressed. The court ordered the reversal of the Appellate Division's order and the dismissal of the indictment. View "People v Lively" on Justia Law

In May 2017, police officers stopped a vehicle driven by the defendant, Jason Brown. The officers claimed they stopped the vehicle because they observed the passenger side door open and close quickly while the car was in motion, leading them to believe someone inside might need assistance. Upon approaching the vehicle, the officers smelled marijuana and subsequently discovered ecstasy in the defendant's possession. The defendant was charged with criminal possession of a controlled substance in the seventh degree.The defendant moved to suppress his statement and the physical evidence recovered, arguing that the stop was unlawful. The suppression court disagreed, concluding that the officers' concern for the safety of the passenger justified the stop, despite the absence of a traffic infraction or reasonable suspicion of criminal activity. The Appellate Term affirmed the judgment, holding that the stop was justified based on considerations of public safety.The New York Court of Appeals reversed the lower courts' decisions. The court recognized a "community caretaking" function, which allows police to stop a moving vehicle under certain circumstances. However, the court held that the police may only stop a vehicle under this function if they can point to specific, objective, and articulable facts that would lead a reasonable officer to conclude that an occupant of the vehicle is in need of assistance, and the police intrusion must be narrowly tailored to address the perceived need for assistance. In this case, the court found that the officers' observation of the car door opening and closing once while the vehicle was in motion did not meet this standard. Therefore, the stop of the defendant's vehicle was unlawful, and the order of the Appellate Term was reversed. View "People v Brown" on Justia Law

The case involves the Roman Catholic Diocese of Albany and other entities, who provide medical insurance plans to their employees. They challenged a regulation by the Department of Financial Services, which requires New York employer health insurance policies that provide hospital, surgical, or medical expense coverage to include coverage for medically necessary abortion services. The plaintiffs argued that the exemption for "religious employers" was too narrow, violating the First Amendment rights of certain types of religiously affiliated employers who do not meet the terms of the exemption.The case began in 2016, raising a federal Free Exercise Claim that was similar to a previous case, Catholic Charities of Diocese of Albany v Serio. The lower courts dismissed the plaintiffs' complaints based on the principle of stare decisis, and the Appellate Division affirmed on the same ground. The plaintiffs appealed to the Supreme Court of the United States, which remanded the case to the Appellate Division to reconsider in light of a recent decision, Fulton v Philadelphia.On remand, the Appellate Division held that Serio was still good law and affirmed its previous decision that neither the medically necessary abortion regulation nor the "religious employer" exemption as defined violated the Free Exercise Clause. The Court of Appeals agreed, stating that under Fulton, both the regulation itself and the criteria delineating a "religious employer" for the purposes of the exemption are generally applicable and do not violate the Free Exercise Clause. The court concluded that the "religious employer" exemption survives the general applicability tests delineated in Fulton, and therefore, the Appellate Division order should be affirmed. View "Roman Catholic Diocese of Albany v Vullo" on Justia Law

The defendant, Samual Nektalov, was a passenger in a vehicle that was stopped by NYPD Detective Gregory Fortunato due to "excessively tinted windows." Upon approaching the vehicle, the detective observed marijuana in plain view and subsequently arrested and searched Nektalov, finding two bags of cocaine. Nektalov moved to suppress the drugs, arguing that the officers lacked probable cause to stop the vehicle based on a traffic violation.The Criminal Court denied Nektalov's motion to suppress the drugs, ruling that the vehicle was properly stopped due to a violation of the Vehicle and Traffic Law for having excessively tinted windows. Nektalov pleaded guilty to criminal possession of a controlled substance in the seventh degree. The Appellate Term affirmed the decision, with one Justice dissenting, holding that the detective's testimony sufficiently established probable cause to lawfully stop the vehicle due to an apparent violation of the Vehicle and Traffic Law.The Court of Appeals disagreed with the lower courts' decisions. The court noted that the Vehicle and Traffic Law generally prohibits operating a vehicle with windows that have a light transmittance of less than 70%. The court found that the detective's testimony that the windows were "excessively tinted" was effectively a legal conclusion that the tint violated the Vehicle and Traffic Law. However, the prosecution failed to elicit any factual basis for this conclusion. The detective did not testify that the windows were so dark that he could not see into the vehicle, that he had training and experience in identifying illegally tinted windows, or that he measured the tint after stopping the vehicle and the results confirmed that the tint level violated the law. As a result, the court concluded that the Criminal Court should have granted Nektalov's motion to suppress. The court reversed the order of the Appellate Term and dismissed the accusatory instrument. View "People v Nektalov" on Justia Law

The case revolves around an incident that occurred on June 30, 2017, when Henry Bello, a former employee of Bronx-Lebanon Hospital (BLH), entered the hospital armed with a rifle and opened fire, killing one doctor and wounding five members of the medical staff, including Justin Timperio, a first-year resident. Bello and Timperio were strangers prior to the shooting; they never worked at BLH at the same time and had no other prior contact. Following the incident, BLH notified the Workers' Compensation Board (WCB) of Timperio's injuries. Timperio also filed a negligence action in federal court against BLH and the store that sold Bello the rifle.The Workers' Compensation Law Judge (WCLJ) determined that Timperio's injuries were compensable under the Workers' Compensation Law (WCL). Timperio appealed to the WCB, which affirmed the decision. However, the Appellate Division reversed the decision, holding that the lack of record evidence establishing any employment-related animus was sufficient to rebut the presumption in WCL § 21 (1) and concluded that the claim was therefore not compensable.The New York Court of Appeals reversed the decision of the Appellate Division. The court clarified the operation of the rebuttable presumption set forth in Workers' Compensation Law § 21 (1), which provides that when an injury arises in the course of a worker's employment, it is presumed to arise out of that worker's employment and therefore is compensable, absent substantial evidence to the contrary. The court held that in cases involving assaults that occur at work, a lack of evidence as to the motivation for the assault does not rebut that presumption. The court concluded that the presumption applied and was unrebutted in this case, and the Appellate Division's contrary conclusion was error. Therefore, the order of the Appellate Division was reversed, and the decision of the Workers' Compensation Board was reinstated. View "In re Timperio v Bronx-Lebanon Hospital" on Justia Law