Justia Civil Rights Opinion Summaries

In 2006, an individual was convicted of first-degree sexual abuse and later subjected to civil management under New York's Mental Hygiene Law due to a "mental abnormality." Initially confined, he was released to a strict and intensive supervision and treatment (SIST) program in 2016. In 2019, he violated SIST conditions by tampering with an alcohol monitoring bracelet, leading to his temporary confinement based on a psychologist's evaluation and a probable cause finding by the court.The Supreme Court initially found probable cause to believe he was a "dangerous sex offender requiring confinement" and ordered his detention pending a final hearing. He filed a habeas corpus petition, arguing that the statutory scheme violated procedural due process by not providing an opportunity to be heard at the probable cause stage. The Supreme Court denied the petition, and the Appellate Division converted the proceeding to a declaratory judgment action, ultimately declaring the statute constitutional.The New York Court of Appeals reviewed the case and upheld the lower court's decision. The court held that the statutory scheme under Mental Hygiene Law § 10.11 (d) (4) appropriately balances individual and state interests. It concluded that the statute provides sufficient procedural safeguards, including a prompt judicial probable cause determination and a full hearing within 30 days, to mitigate the risk of erroneous confinement. The court found that the petitioner failed to demonstrate that the statute is unconstitutional either on its face or as applied to him. The order of the Appellate Division was affirmed without costs. View "People ex rel. Neville v Toulon" on Justia Law

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

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 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

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 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 case involves a group of convicted sex offenders who were confined in the Fishkill Residential Treatment Facility (RTF) while on post-release supervision (PRS). The Department of Corrections and Community Supervision (DOCCS) used the Fishkill RTF to confine these offenders past their maximum sentence expiration dates because they were unable to find housing that complied with the Sexual Assault Reform Act (SARA). The plaintiffs initiated a proceeding in 2016, seeking injunctions, declaratory relief, and class certification, arguing that DOCCS's operation of the Fishkill RTF failed to comply with the statutes governing RTFs because it did not offer adequate programming or employment opportunities.The Supreme Court dismissed part of the proceeding and converted the remaining into an action seeking a declaration that DOCCS's operation of the Fishkill RTF was non-compliant with the statutes governing RTFs. The court denied class certification, reasoning that the converted declaratory judgment action would adequately protect the interests of similarly situated offenders. After discovery, the defendants moved for summary judgment and a declaration in their favor. The Supreme Court granted defendants' motion in part, concluding that the internal programming was minimally adequate to satisfy DOCCS's statutory obligations. However, the court agreed with plaintiffs that DOCCS failed to provide adequate community-based opportunities.The Appellate Division modified the judgment by reversing the part that granted partial summary judgment to plaintiffs and granted defendants' motion in its entirety. The Court concluded that while the statute requires DOCCS to locate RTFs near a community with employment, training, and educational opportunities, there was no mandate that DOCCS offer such opportunities outside the facility.The Court of Appeals held that DOCCS's wholesale refusal to secure community-based opportunities for Fishkill RTF residents constitutes a violation of the statute. The Court concluded that DOCCS, at a minimum, must undertake reasonable efforts to secure community-based opportunities for those persons subject to its RTF programming. However, the Court agreed with the Appellate Division that the internal programming at the Fishkill RTF was at least minimally adequate. View "Alcantara v Annucci" on Justia Law

The case involved two separate lawsuits against the City of New York, where the plaintiffs, Luis Jaime and Adan Orozco, were seeking permission to serve late notices of claim for alleged intentional torts committed by City employees. The claims were based on the General Municipal Law § 50-e (5), which allows for late notices if the court believes the City has actual knowledge of the essential facts constituting the claims.In Orozco's case, he claimed that officials of the New York City Police Department (NYPD) and the District Attorney's Office obtained a warrant for his arrest without probable cause and used false evidence. Jaime, who was detained at Riker's Island, alleged that he was attacked by correction officers and/or inmates on multiple occasions. Both plaintiffs argued that the City had actual knowledge of their claims due to the involvement of its employees and its possession of related records.The Court of Appeals disagreed with the lower courts' decision to grant the plaintiffs leave to serve late notices of claim. It held that mere participation of City's employees in an intentional tort and the City's possession of related records do not necessarily provide the City with actual knowledge of the essential facts of the claims. The court found that both plaintiffs failed to provide substantive evidence to establish the City's actual knowledge. It also found that their reasons for late filing, such as defending against criminal charges and the effects of the COVID-19 pandemic, did not constitute a reasonable excuse. Consequently, the Court of Appeals reversed the orders of the Appellate Division, denying the plaintiffs' petitions to file late notices of claim. View "Matter of Jaime v City of New York" on Justia Law

In this case, the appellant, Tax Equity Now NY LLC (TENNY), challenged the property-tax system of New York City, arguing that it imposes substantially unequal tax bills on similarly valued properties that bear little relationship to the properties' fair market value. TENNY further alleged that multi-million-dollar properties are taxed at similar or lower rates than less valuable properties and that real property in majority-people-of-color districts are overassessed and subjected to higher taxes compared to properties in majority-white districts. The plaintiff sought relief against City and State defendants for alleged constitutional and statutory violations caused by the City's tax scheme.The Court of Appeals of New York concluded that although TENNY's complaint failed to state claims against the State defendants, the complaint sufficiently alleges causes of action against the City defendants under section 305 (2) of Real Property Tax Law (RPTL) and the federal Fair Housing Act (FHA) on the basis that the system is unfair, inequitable and has a discriminatory disparate impact on certain protected classes of New York City property owners. The court therefore modified the Appellate Division's order with respect to these causes of action. The court also affirmed the dismissal of the remaining causes of action against the City and all claims against the State for failure to state a claim. View "Tax Equity Now NY LLC v City of New York" on Justia Law

The case involves a plaintiff, Nafeesa Syeed, an Asian-American woman who sued Bloomberg L.P., alleging employment discrimination. She claimed she was subjected to discrimination due to her sex and race while working for Bloomberg's Washington, D.C. bureau, and was denied promotions for positions she sought within Bloomberg's New York bureau.The United States District Court for the Southern District of New York dismissed her claims under both the State and City Human Rights Laws, stating that she could not show how Bloomberg's conduct impacted her in New York State or City, as she neither lived nor worked there. The court held that the Human Rights Laws applied only to people who live or work in New York.This decision was appealed, and the Second Circuit certified a question to the New York Court of Appeals: whether a nonresident plaintiff not yet employed in New York City or State satisfies the impact requirement of the New York City Human Rights Law or the New York State Human Rights Law if the plaintiff pleads and later proves that an employer deprived the plaintiff of a New York City- or State-based job opportunity on discriminatory grounds.The Court of Appeals held that the New York City and New York State Human Rights Laws each protect nonresidents who are not yet employed in the city or state but who proactively sought an actual city- or state-based job opportunity. The court reasoned that a nonresident who has been discriminatorily denied a job in New York City or State loses the chance to work, and perhaps live, within those geographic areas, and such a prospective inhabitant or employee fits within the Human Rights Laws' protection. The court highlighted that their decision was in line with the policy considerations addressed in the Human Rights Laws, protecting New York institutions and the general welfare of the state and city. View "Syeed v Bloomberg L.P." on Justia Law