Justia New York Court of Appeals Opinion Summaries

In 2000, Defendant pleaded guilty to first-degree manslaughter and was sentenced to twenty-three years incarceration. After Defendant’s incarceration, the Department of Correctional Services added a five-year PRS term to her certificate of commitment. In 2009, Defendant filed a pro se motion claiming that her plea was defective and her sentence illegal because she was not informed before she was incarcerated that she would be required to serve an additional term of PRS. Defendant was resentenced to the original sentence of twenty-three years without a term of PRS. Defendant appealed the resentence. Defendant’s counsel filed a motion under People v. Crawford asking to be relieved as counsel because there were no non-frivolous issues to be raised on Defendant’s behalf. Defendant subsequently filed a pro se supplemental brief arguing, inter alia, that the sentence was illegal. The appellate division granted counsel’s motion and affirmed the resentence without addressing Defendant’s pro se contentions. The Court of Appeals reversed, holding that the appellate division erred in granting the Crawford motion, and therefore, remittal for a de novo appeal was warranted.View "People v. Beaty" on Justia Law

Plaintiff was being treated at a private medical facility, a nurse employed by the clinic committed an unauthorized disclosure of Plaintiff’s confidential health information. Plaintiff filed this action in federal court against Defendants, various affiliated entities that allegedly owned or otherwise controlled the clinic. The district court granted Defendants’ motion to dismiss all eight of Plaintiff’s claims. The Second Circuit Court of Appeals affirmed the dismissal of all but one of Plaintiff’s causes of action, reserving decision on Plaintiff’s claim of breach of fiduciary duty. In a separate opinion, the Second Circuit found the nurse’s actions were not foreseeable to Defendants nor taken within the scope of her employment. The court, however, certified a question to the New York Court of Appeals regarding Defendants’ liability where respondeat superior liability is absent. The Court of Appeals answered that, under New York law, the common law right of action for breach of the fiduciary duty of confidentiality for the unauthorized disclosure of medical information may not run directly against medical corporations when the employee responsible for the breach acts outside the scope of her employment. View "Doe v. Guthrie Clinic, Ltd." on Justia Law

Defendant, a high school student, anonymously posted sexual information and photographs of fellow classmates and other adolescents on Facebook, a social networking website. Defendant was charged with and pleaded guilty to cyberbullying under a local law enacted by the Albany County Legislature. Defendant appealed, arguing that the cyberbullying law violated the Free Speech Clause of the First Amendment. The Court of Appeals reversed, holding that Albany County’s cyberbullying law was overbroad and facially invalid under the Free Speech Clause because the text of the law criminalized a variety of constitutionally-protected modes of expression - a great deal more than acts of cyberbullying. View "People v. Marquan M." on Justia Law

Plaintiff brought an action against Volvo Cars of North America, alleging defective design of a product. The case proceeded to trial. At Plaintiff’s request, the trial court included a pattern jury instruction to charge the jury that was the same standard jury charge in malpractice actions. The instruction tells the jury that a defendant who has special skills in a trade or profession is required to use the same degree of skill and care that others in the same trade or profession would reasonably use in the same situation. A jury rendered a verdict in favor of Plaintiff. The Court of Appeals reversed, holding that because this was not a malpractice case but a design defect case, the charge should not have been given, and the error required reversal and a new trial. View "Reis v. Volvo Cars of N. Am." on Justia Law

These two cases involved the dissolution of two separate law firms. After the law firms’ dissolution, the partners joined other law firms, which took on unfinished legal matters from the dissolved law firms’ former clients. The dissolved law firms subsequently filed for bankruptcy. Separate adversary proceedings were brought against the law firms that hired the dissolved law firms’ partners. The lawsuits were premised on the unfinished business doctrine, and the plaintiffs sought to recover the value of the dissolved law firms’ business for the benefit of the estate’s creditors. At issue before the Court of Appeals was whether, for purposes of administering a related bankruptcy, New York law treats a dissolved law firm’s pending hourly fee matters as its property. The Court of Appeals held that pending hourly fee matters are not partnership property or unfinished business within the meaning of New York’s Partnership Law, as a law firm does not own a client or an engagement and is only entitled to be paid for services actually rendered. View "In re Thelen LLP" on Justia Law

Defendant was charged with numerous crimes arising from his theft of a minivan and the death of a pedestrian that the minivan struck during a high-speed police chase. After a jury trial, Defendant was found guilty of depraved indifference murder, unlawful fleeing of a police officer in a motor vehicle in the first degree, and grand larceny in the fourth degree. On appeal, Defendant asserted that there was insufficient evidence to support his depraved indifference murder conviction. The Court of Appeals modified the Appellate Division’s order by reducing Defendant’s depraved indifference murder conviction to manslaughter in the second degree, holding that the evidence in this case was legally insufficient to support the conviction because the circumstances did not fit within the narrow category of cases wherein the facts evince a defendant’s utter disregard for human life. View "People v. Maldonado" on Justia Law

After a jury trial, Defendant was convicted of grand larceny and money laundering, both in the second degree, for defrauding the former New York City Mayor, Michael Bloomberg, of $750,000. The Appellate Division affirmed the convictions. On appeal, Defendant argued that the testimony regarding the source of the stolen funds violated the best evidence rule and that, without the testimony, the evidence was insufficient to support the conviction. The Court of Appeals affirmed, holding (1) by the time Defendant raised his objection, other testimony was given that tended to prove ownership, and therefore, the best evidence rule challenge was of no consequence; and (2) nevertheless, the testimony was not so prejudicial as to deny Defendant a fair trial. View "People v. Haggerty" on Justia Law

After a jury trial, Defendant was convicted of two counts of murder in the second degree. The Appellate Division affirmed on direct appeal. Approximately a decade later, Defendant moved to vacate his judgment of conviction, asserting that the People committed a Brady violation by failing to disclose to him that a federal civil action had been brought against one of their police witnesses, a homicide detective who interrogated Defendant, based on the detective’s alleged police misconduct in an unrelated case. The Appellate Division remitted the matter for a hearing, determining that the civil allegations against the detective constituted impeachment evidence and that the People’s failure to disclose them may have deprived Defendant of a fair trial. The Court of Appeals reversed, holding that, although the civil allegations were favorable to Defendant, he failed to prove that the People suppressed the information or that he was prejudiced by the undisclosed information. View "People v. Garrett" on Justia Law

In 1996, Defendant pleaded guilty to third-degree sale of a controlled substance. In 2010, citing Padilla v. Kentucky, Defendant moved to vacate his conviction on the ground that defense counsel was ineffective for failing to advise him of the immigration consequences of his guilty plea. Supreme Court declined to apply Padilla retroactively to Defendant’s claim. The Appellate Division disagreed with Supreme Court, holding that Padilla was to be retroactively applied to pleas after Congress made significant changes in immigration law in 1996. The United States Supreme Court subsequently decided Chaidez v. United States, holding that Padilla does not apply retroactively in federal collateral review. After Chaidez was decided, the Court of Appeals in the instant case reversed the Appellate Division’s order, holding that, pursuant to federal or state retroactivity principles, Padilla does not apply retroactively in state court postconviction proceedings. View "People v. Baret" on Justia Law

These two appeals concerned the efforts of two corporations to explore and develop natural gas resources in two municipalities. In response, both municipalities adopted amendments to their zoning laws that prohibited all oil and gas exploration. The corporations brought actions challenging the zoning laws. Supreme Court declared the zoning laws valid, and the Appellate Division affirmed. The Court of Appeals affirmed, holding that the supersession clause in the statewide Oil, Gas and Solution Mining Law does not preempt the home rule authority vested in municipalities to regulate oil and gas production activities, including hydrofracking, within municipal boundaries through the adoption of zoning laws. View "Wallach v. Town of Dryden " on Justia Law