Justia Civil Rights Opinion Summaries

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

After a jury trial, Defendant was found guilty of course of sexual conduct against a child in the first degree and endangering the welfare of a child. The Appellate Division affirmed the judgment. Defendant filed a motion for post-conviction relief, asserting that his trial counsel provided ineffective assistance by (1) failing to oppose the admission and use of prior consistent statements of the child victim, which bolstered her credibility, and (2) failing to consult or present testimony from a qualified independent medical expert to support his argument that no sexual abuse occurred. The Court of Appeals affirmed, holding that the record clearly indicated that Defendant’s trial counsel was not ineffective in this case. View "People v. Gross" on Justia Law

In 2002, Plaintiffs commenced a proposed class action civil rights suit against the County of Rensselaer. The County invoked Selective Insurance Company’s duty to provide a defense under the policies that the company sold to the County. Selective agreed to defend the County in the action, subject to the insurance policy limits and the deductible. Selective’s counsel and the County agreed to settle the actions for $1,000 per plaintiff, determined to be slightly more than 800 individuals in total, with attorney fees also being recoverable. Selective abided by the terms of the settlement. The County, however, refused to pay Selective more than a single deductible payment. Selective then commenced this action for money damages, arguing that each class member was subject to a separate deductible. Supreme Court concluded that a separate deductible payment applied to each class member and that all legal fees should be allocated to one policy. The Appellate Division affirmed. The Court of Appeals affirmed, holding that the class action suit did not constitute one occurrence under the relevant policies’ definition of “occurrence” and that the attorney’s fees generated in defending that suit were properly allocated to the named plaintiff. View "Selective Ins. Co. of Am. v. County of Rensselaer" on Justia Law

Defendant was convicted of two counts of first degree murder and one count of criminal possession of a weapon in the second degree. Defendant appealed, arguing that the People improperly used his silence, in the immediate aftermath of his arrest, against him in violation of his constitutional rights and that he was denied a fair trial due to defense counsel’s ineffectiveness. The Appellate Division affirmed. The Court of Appeals affirmed, holding (1) the People’s use of Defendant’s silence constituted a violation of his state constitutional rights, but the error was harmless; and (2) Defendant failed to establish that his attorney failed to provide meaningful representation that compromised his right to a fair trial. View "People v. Pavone" on Justia Law

The two defendants in these cases accepted pleas to criminal offenses. Defendants later petitioned for writs of error coram nobis, each alleging that counsel was constitutionally ineffective by failing to advise Defendants of their right to appeal. Defendants also alleged had they known about their right to appeal, they would have requested one. In each case, the Appellate Division denied the defendant’s writ of error coram nobis. The Court of Appeals affirmed, holding that under the circumstances of these two cases, Defendants failed to meet their burden on their coram nobis applications, as the records as a whole revealed that Defendants knew about their right to appeal. View "People v. Rosario" on Justia Law

Defendant was convicted of sexual conduct against a child in the second degree, rape in the second degree, and two counts of endangering the welfare of a child. Defendant appealed, arguing that his trial counsel provided ineffective assistance for failing to seek the dismissal of time-barred charges against him and by failing to object to certain statements by the prosecutor during her summation. The Appellate Division affirmed. The Court of Appeals affirmed, holding (1) given the presence of a plausible and reasonable strategy that could explain counsel’s action, defense counsel was not ineffective for failing to seek dismissal of the time-barred charges; and (2) Defendant’s counsel was not ineffective for failing to object to certain statements made during the prosecutor’s summation. View "People v. Ambers" on Justia Law

Defendant was indicted for burglary in the second degree and petit larceny. The burglary charge was timely interposed but the petit larceny charge was not, as the applicable statutory period ran approximately one and one-half years before the filing of the accusatory instrument. Defendant’s counsel never obtained the time-barred count’s dismissal, and Defendant was convicted of both indicted offenses. Defendant appealed, arguing that the trial court erred in denying his for-cause challenge to a prospective juror and that he received ineffective assistance of counsel at trial. The Appellate Division affirmed the judgment of conviction. The Court of Appeals modified the judgment by vacating Defendant’s conviction on the charge of petit larceny and dismissing that charge in the indictment, holding that the failure of Defendant’s counsel to have the time-barred petit larceny count dismissed constituted ineffective assistance. View "People v. Harris" on Justia Law

After a jury trial, Defendant was convicted of sexual assault in the first degree. The trial court sentenced Defendant as a second child sexual assault felony offender to a determinate term of fifteen years with five years of post-release supervision. The Appellate Division affirmed. Defendant appealed, arguing that his right to a fair trial was violated because of alleged critical mistakes by his trial counsel. The Court of Appeals affirmed, holding that Defendant failed to establish that defense counsel made the type of missteps that establish a performance so lacking in competence and strategic purpose that it failed to meet the constitutional minimum standard of professionalism recognized by the Court. View "People v. Wragg" on Justia Law