Justia Civil Rights Opinion Summaries

After a jury trial, Defendant was convicted of attempted murder and two counts of assault in the first degree. Defendant, who was fifteen years old at the time of the crime, challenged the judgment of conviction on direct appeal, arguing that he received ineffective assistance of counsel. The Appellate Division reversed, concluding that defense counsel provided ineffective assistance by withholding information from an expert in child and adolescent psychiatry. The Court of Appeals reversed, holding (1) Defendant received meaningful and effective representation; and (2) Defendant failed to demonstrate the absence of strategic or other legitimate explanations for counsel’s alleged shortcomings. View "People v. Henderson" on Justia Law

After a trial, Defendant was convicted of criminal possession of a weapon in the second degree and menacing in the second degree. Defendant appealed, arguing that the trial court violated his constitutional right to confront the witnesses against him by permitting the People to introduce DNA reports into evidence providing that Defendant’s DNA profile was found on the gun that was the subject of the charged possessory weapon offense without producing a single witness who conducted, witnessed, or supervised the laboratory’s generation of the DNA profile from the gun or Defendant’s exemplar. The Appellate Division affirmed. The Court of Appeals reversed and ordered a new trial, concluding that an analyst who witnessed, performed or supervised the generation of Defendant’s DNA profile, or who used his or her independent analysis on the raw data, must be available to testify. View "People v. John" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree and related crimes. Defendant appealed, arguing that the trial court erred in precluding him from presenting third-party culpability evidence. The Appellate Division affirmed. The Court of Appeals affirmed, holding (1) the standard set forth in People v. Primo that third-party culpability evidence should be evaluated in accordance with ordinary evidentiary principles does not infringe upon a defendant’s constitutional right to present a complete defense; and (2) applying the Primo standard in this case, the trial court did not abuse its discretion by precluding Defendant’s “ill-defined and speculative” third-party culpability evidence. View "People v. Powell" on Justia Law

Defendant was charged with murder. Defendant filed a motion to suppress his initial statement made to a police detective, as well as a statement he made after a forty-five-minute break, on the grounds that the detective failed to issue a complete set of Miranda warnings at the outset of the interview. The hearing court granted the motion to suppress. The Appellate Division reversed and denied the suppression motion, concluding that Defendant’s second statement had been attenuated from the first. After a trial, the jury returned a verdict convicting Defendant of murder in the second degree. Defendant moved to vacate the judgment, alleging that defense counsel had provided ineffective assistance by failing to move to reopen the suppression hearing based on the detective’s trial account of the statement made by Defendant prior to the issuance of the Miranda warnings. Supreme Court denied Defendant’s post-judgment motion without a hearing. The Appellate Division affirmed. The Court of Appeals affirmed, holding that counsel had a reasonable trial strategy, and therefore, Defendant was not entitled to relief on his ineffective assistance claim. View "People v. Gray" on Justia Law

Defendant was found guilty of murder in the second degree, attempted murder in the second degree, and related charges. The Appellate Division reversed the judgment and ordered a new trial. At the second trial, a witness that had been unavailable at the first trial testified for the prosecution. When asked if he was at the scene of the shooting, the witness invoked his Fifth Amendment privilege against self-incrimination. Defendant appealed, arguing that the witness’s invocation of his Fifth Amendment privilege added “critical weight” to the People’s case, that the witness’s testimony deprived him of a fair trial, and that the trial court erred in allowing the People to impeach the witness with his prior inconsistent statements. The Appellate Division affirmed. The Court of Appeals affirmed, holding (1) the prosecution did not exploit the witness’s invocation of his Fifth Amendment privilege, and therefore, the witness was properly called; (2) the trial court did not err in allowing the People to introduce the witness’s prior statement for the limited purpose of impeaching him; and (3) the trial court did not err in precluding Defendant's identification expert from testifying about the effect of stress on the accuracy of an identification. View "People v. Berry" on Justia Law

After a joint trial, Defendant was found guilty of robbery in the second degree, petit larceny, menacing in the second degree, and possession or use of an imitation pistol or revolver. Defendant appealed, arguing that the trial court erred in admitting a non-testifying codefendant’s grand jury testimony under Bruton v. United States because the statements were facially incriminating as to Defendant. The Appellate Division agreed with Defendant and reversed the judgment and remanded for a new trial. The Court of Appeals affirmed, holding that the trial court’s admission of the codefendant’s statements, which were incriminating as to Defendant in the constitutional sense, was error, and the error was not harmless. View "People v. Johnson" on Justia Law

After a jury trial, Defendant was convicted of first-degree gang assault and fourth-degree weapons possession and sentenced to an aggregate term of sixteen years in prison. Defendant appealed, arguing that the admission of a nontestifying codefendant’s redacted statement to law enforcement officers violated Defendant’s rights under the Confrontation Clause of the Sixth Amendment. The Appellate Division affirmed. The Court of Appeals reversed, holding that because the redacted statement was facially incriminating, the admission of the statement violated Defendant’s rights under the Confrontation Clause, as discussed in Bruton v. United States, and the error was not harmless. View "People v. Cedeno" on Justia Law

After a jury trial, Defendant was convicted of burglary in the first degree. The Appellate Division affirmed. The Court of Appeals affirmed, holding (1) the trial court did not commit a mode of proceedings error when it allowed prospective jurors to opt out of serving on the jury due to hardship; (2) the trial court did not err in precluding third-party culpability evidence proferred by the defense; and (3) Defendant was not deprived of the effective assistance of counsel due to trial counsel’s failure to object to certain inflammatory statements made by the prosecutor during summation. View "People v. King" on Justia Law

Defendant was treated at Hospital for a gunshot wounds. Hospital reported the shooting to the police. By the time Defendant spoke to an officer, Defendant was wearing hospital clothing. The officer subsequently seized the bag containing the clothing that Defendant wore when he came to Hospital. After the officer inspected the garments, authorities came to believe the Defendant had accidentally shot himself with a gun he carried in his waistband. Defendant was charged with, inter alia, criminal possession of a weapon in the second degree and criminal possession of a weapon in the third degree. Defendant sought to suppress the clothes based on the “unlawful warrantless seizure of those items.” Supreme Court denied suppression. After a jury trial, Defendant was convicted. The Appellate Division affirmed. The Court of Appeals reversed, holding that the seizure was illegal and that the items seized were improperly admitted into evidence at trial. View "People v. Sanders" on Justia Law

After a jury trial, Defendant, a Chinese immigrant, was found guilty of murder, burglary and attempted robbery. The Appellate Division affirmed the judgment. Defendant appealed, arguing (1) his confession to law enforcement officers was an involuntary product of untoward psychological pressure and fatigue, and (2) due to his limited English language proficiency, he did not understand the import of the Miranda warnings given to him, and therefore, he did not knowingly and voluntarily waive his Miranda rights. The Court of Appeals affirmed, holding (1) the totality of the circumstances did not establish that Defendant’s will was so overborne as to make his confession involuntary; and (2) there was record support for the lower courts’ determinations that Defendant understood the import of his Miranda rights. View "People v. Jin Cheng Lin" on Justia Law