Justia Civil Rights Opinion Summaries

In 1979, Plaintiff began his employment with Defendant, New York City Health and Hospitals Corporation (HHC), where he was eventually promoted to health facilities planner. In 2005, Plaintiff was diagnosed with pneumoconiosis, an occupational lung disease. In 2007, Defendant terminated Plaintiff. In 2008, Plaintiff filed a complaint alleging, among other claims, that HHC had unlawfully discriminated on the basis of disability in violation of the State Human Rights Law (State HRL) and the City Human Rights Law (City HRL). Supreme Court granted summary judgment for HHC, concluding that Plaintiff could not, even with a reasonable accommodation, perform the essential functions of his job. The Appellate Division affirmed. The Court of Appeals affirmed as modified, holding that HHC was not entitled to summary judgment with respect to Plaintiff’s State HRL and City HRL claims, as (1) both statutes generally preclude summary judgment in favor of an employer where the employer has failed to demonstrate that it responded to a disabled employee’s request for a particular accommodation by engaging in a good faith interactive process regarding the feasibility of that accommodation; and (2) under the facts of this case, Plaintiff presented colorable claims of disability discrimination under the City HRL and State HRL. View "Jacobsen v. New York City Health & Hosps. Corp." on Justia Law

After a jury trial, Defendant was found guilty of murder in the second degree for suffocating her stepdaughter. The Appellate Division found the jury verdict was against the weight of the evidence and modified the County Court’s judgment by reducing the murder conviction to a conviction of second-degree manslaughter. The Court of Appeals affirmed, holding (1) Defendant’s confession to the police following the child’s death was sufficiently corroborated by independent evidence at trial to support Defendant’s conviction; (2) the trial court did not abuse its discretion in admitting certain letters into evidence, as they were sufficiently redacted; and (3) Defendant was not denied effective assistance of trial counsel. View "People v. Santiago" on Justia Law

Upon responding to a burglary report at an apartment building, police officers observed Defendant in the building’s stairwell. When the officers arrested Defendant for trespassing, one of the officers opened Defendant’s shoulder purse, which contained a loaded handgun. Defendant was subsequently indicted for criminal possession of a gun in the second degree and criminal trespass in the second degree. The trial court denied Defendant’s motion to suppress the gun, and, after a jury trial, Defendant was convicted of the counts charged. The Court of Appeals reversed, holding (1) the People bear the burden of demonstrating the presence of exigent circumstances in order to conduct a warrantless search of a closed container incident to arrest; and (2) in this case, the People failed to meet that burden as a matter of law. View "People v. Jimenez" on Justia Law

After a jury trial, Defendant was convicted of depraved indifference murder for murdering his infant son. The Appellate Division affirmed Defendant’s conviction. The Supreme Court reversed and directed a new trial, holding (1) the evidence was sufficient to demonstrate that Defendant, with depraved indifference to human life, recklessly engaged in conduct that created a grave risk of serious physical injury to the four-month-old, thereby causing the child’s death; but (2) Defendant’s previously denied motion to suppress inculpating statements he made to interrogators was in error because the statements were not demonstrably voluntary, and Defendant’s confession should not have been placed before the jury. View "People v. Thomas" on Justia Law

After a nonjury trial, Defendant was convicted of unlawful surveillance in the second degree for standing outside the front door of his neighbor’s townhouse and filming the complainant while she was naked in her second floor bathroom. Defendant appealed, arguing that insufficient evidence supported his conviction. The Appellate Division affirmed, concluding that the evidence established that Defendant had surreptitiously recorded the complainant for his own amusement at a time and place where she had a reasonable expectation of privacy. The Court of Appeals affirmed, holding that each element of the offense of unlawful surveillance in the second degree was established beyond a reasonable doubt. View "People v. Schreier" on Justia Law

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

In the first case involved in this appeal, Defendant pleaded guilty to criminal possession of marihuana. Defendant appealed, asserting that his plea was invalid because the record did not affirmatively demonstrate the waiver of his Boykin rights. The Appellate Term affirmed. In the second case, Defendant pleaded guilty to criminal sale of marihuana. Defendant appealed, arguing, as in the first case, that the waiver of his Boykin rights was nonexistent. The Appellate Term affirmed. The Court of Appeals reversed in both cases, holding that because the records in both cases were silent as to Defendant's waiver of his Boykin rights, the pleas must be vacated. View "People v. Tyrell" on Justia Law

After a jury trial, Defendants were convicted of first-degree robbery. Defendants appealed, arguing, among other things, that their counsel provided ineffective assistance by failing to assert as an affirmative defense that one of two weapons displayed during the gunpoint robbery was not "a loaded weapon from which a shot, readily capable of producing death or serious physical injury, could be discharged" pursuant to N.Y. Penal Law 160.15. The Appellate Division affirmed. The Court of Appeals affirmed, holding (1) defense counsel were not ineffective for neglecting to challenge the sufficiency of the evidence or for failing to put the affirmative defense before the jury; and (2) the record supported the lower courts' determination that the robbery victim's showup identification of Defendants was proper. View "People v. Howard" on Justia Law

Defendants in these three consolidated appeals were convicted of depraved indifference murder for driving in an outrageously reckless manner while intoxicated by alcohol or drugs and causing the death of at least one other person. Defendants challenged their convictions, contending that the evidence was not legally sufficient to support their convictions. Specifically, Defendants asserted that there was insufficient proof they had the requisite mental state of depraved indifference. The Court of Appeals affirmed the convictions, holding that there was sufficient evidence in each case that Defendants were aware of and appreciated the risks caused by their behavior. View "People v. Heidgen" on Justia Law

After a jury trial, Appellant was convicted of sexual abuse in the first degree and endangering the welfare of a child. Prior to Appellant's release from prison, the Department of Correctional Services transferred Appellant to Kirby Psychiatric Center. During his confinement at Kirby, the State filed a N.Y. Mental Hyg. Law 10 civil management petition against Appellant. A jury found that Appellant suffered from a mental abnormality, and the court assigned him to the Office of Mental Health for confinement in a secure facility. Appellant appealed, arguing, inter alia, that Supreme Court erred when it allowed experts to testify to unreliable hearsay when the hearsay served as the underlying basis for the experts' opinion. The Appellate Division affirmed. The Court of Appeals reversed and ordered a new trial, holding (1) the trial court improperly permitted the State's experts to introduce certain unreliable hearsay as well as some hearsay with a patina of reliability that nevertheless was more prejudicial than probative as a matter of law; and (2) these errors denied Appellant due process. View "State v. Floyd Y." on Justia Law