Justia Civil Rights Opinion Summaries

At issue in these consolidated criminal appeals was whether, prior to permitting a defendant to plead guilty to a felony, a trial court must inform the defendant, if the defendant is not U.S. citizen, that he or she may be deported as a result of the plea. The Court of Appeals held that due process compels a trial court to apprise a defendant that, if the defendant is not a U.S. citizen, he or she may be deported as a consequence of a guilty plea to a felony. In so holding, the Court (1) overruled the portion of its decision in People v. Ford which held that a court's failure to advise a defendant of potential deportation does not affect the validity of the defendant's plea; and (2) held that the trial court's failure to notify a pleading non-citizen defendant of the possibility of deportation does not entitle the defendant to automatic withdrawal or vacatur of the plea, but rather, in order to overturn his or her conviction, the defendant must establish the existence of a reasonable probability that, had the court warned the defendant of potential deportation, the defendant would have rejected the plea and opted to go to trial. View "People v. Peque" on Justia Law

Defendant was charged with one count of criminal possession of a weapon in the second degree for possessing a loaded firearm. The count was based on evidence that a loaded gun was found in Defendant's home. With the indictment, the People filed a special information alleging that Defendant had previously been convicted of criminal possession of a controlled substance in the first degree. Supreme Court reduced the charge to third degree possession. The Appellate Division reversed and reinstated the second degree charge. At issue on appeal was whether Defendant was entitled to rely on the so-called "home or business" exception in the definition of second degree weapon possession despite his prior conviction. The Court of Appeals affirmed, holding that because Defendant had a previous conviction, the exception did not apply. View "People v. Jones" on Justia Law

Defendant, a convicted criminal, was convicted of the class C felony of criminal possession of a weapon in the second degree and sentenced to three and one-half years in prison for possessing a loaded weapon in his home. Defendant appealed, arguing that, while the State did have power to punish him for having an unlicensed handgun in his home, his conviction infringed on his Second Amendment right to keep and bear arms where his punishment was unusually severe. The Appellate Division affirmed the conviction and sentence. The Court of Appeals affirmed, holding that Defendant's sentence did not raise constitutional problems in this case. View "People v. Hughes" on Justia Law

Petitioners were current and former elected officials and appointed officers of the Village of Freeport. In 2008, Water Works Realty Corp. commenced lawsuits against the Village and Petitioners alleging, inter alia, violations of the Racketeer Influenced and Corrupt Organization Act. The Freeport Board of Trustees authorized the Village to defend and indemnify Petitioners, but after Petitioners refused to settle with Water Works due to Water Works' requirement that Petitioners sign a stipulation of discontinuance containing a nondisparagement clause, the Village withdrew Petitioners' defense and indemnification. Petitioners subsequently filed an action seeking a judgment directing the Village to provide a defense. Supreme Court denied the request. The Court of Appeals affirmed, holding that the municipality could withdraw its defense and indemnification of Petitioners for their failure to accept a reasonable settlement offer, and Petitioners' First Amendment concerns with respect to the settlement's nondisclosure clause did not warrant a different conclusion. View "Lancaster v. Inc. Vill. of Freeport" on Justia Law

Defendant was arrested for driving while intoxicated. Defendant moved to suppress the evidence found inside his car, arguing that it was obtained by police during an invalid inventory search. Supreme Court denied the suppression motion, and Defendant pled guilty. The Appellate Division affirmed, concluding that the inventory search was improper but that Defendant's guilty plea nonetheless was valid under People v. Lloyd, which recognized exceptions to the principle established in People v. Grant that the harmless error doctrine generally cannot be used to uphold a guilty plea that is entered after the improper denial of a suppression motion. The Court of Appeals reversed, holding that the erroneous denial of Defendant's motion to suppress was not harmless because there was not sufficient independent proof of Defendant's guilt. View "People v. Wells" on Justia Law

After a jury trial, Defendant was convicted of second-degree manslaughter, second-degree assault, third-degree assault, reckless endangerment, and reckless driving. The Appellate Division affirmed. Defendant appealed, arguing that there was insufficient evidence to sustain the second-degree manslaughter and second-degree assault convictions. The Court of Appeals affirmed, holding that the proof was legally sufficient to prove Defendant's guilt beyond a reasonable doubt where the evidence demonstrated that Defendant (1) engaged in conduct exhibiting "the kind of seriously blameworthy carelessness whose seriousness would be apparent to anyone who shares the community's general sense of right and wrong," and (2) acted with the requisite mens rea of recklessness by consciously disregarding the risk he created. View "People v. Asaro" on Justia Law

Defendant was indicted for various drug offenses. At a Huntley hearing, the county court judge informed the parties that he may have either represented or prosecuted Defendant on unrelated criminal matters in the past, but neither party object to the judge's continuing to preside over the matter. Later, however, Defendant requested that the judge recuse himself based on the judge's prior representation of him. The judge denied the motion, ultimately finding no reason to disqualify himself. After a jury trial, Defendant was convicted of several counts of criminal possession of marijuana. The Appellate Division affirmed the judgment, holding that the judge's recusal was not warranted and that Defendant received meaningful representation. The Court of Appeals affirmed, holding (1) the judge did not abuse his discretion in refusing to recuse himself; and (2) Defendant was not denied effective assistance of counsel. View "People v. Glynn" on Justia Law

Defendant was arrested after law enforcement officers noticed him walking on a roadway with wet blood stains on his clothes, hands, and shoes. Because the officers believed a person may have been injured, they continued to question Defendant despite his request for legal assistance. Eventually, officers discovered Defendant's business partner lying dead in his driveway. Defendant was indicted for second-degree murder and moved to suppress statements he made to the police and an acquaintance, as well as the physical evidence, claiming he had been arrested without probable cause and interrogated in violation of his right to counsel and without having received Miranda warnings. The county court ruled that the detention and questioning of Defendant were justified under the emergency doctrine. After a jury trial, Defendant was convicted as charged. The Court of Appeals affirmed, holding (1) the record supported the determination that the emergency doctrine justified the police questioning; and (2) the courts below did not err in finding that Defendant's assertions were voluntary and admissible at trial. View "People v. Doll" on Justia Law

After a jury trial, Defendant was convicted of possession of a weapon not in his home or place of business and sentenced to a term of imprisonment. The Appellate Division affirmed. Appellant appealed, arguing that the trial court's admission of a 911 telephone call reporting that a person matching Defendant's description committed an uncharged gunpoint robbery and police testimony describing the radio run they received about the call deprived him of a fair trial. The Court of Appeals affirmed, holding that, under the circumstances of this case, the trial court did not abuse its discretion by permitting the 911 evidence to be admitted, along with several limiting instructions, as background information to explain the aggressive police action toward Defendant. View "People v. Morris" on Justia Law

Appellant owned a part-time residence in New York but intended to make Louisiana his primary residence. Appellant applied for a New York State pistol/revolver license pursuant to N.Y. Penal Law 400.00 and inquired whether he would still be eligible for a handgun license. The county court judge denied Appellant's application for a handgun license, concluding that the term "residence" was equivalent to "domicile," and therefore, because Appellant was not domiciled in New York, he was ineligible for the license. Appellant commenced this action pursuant to 42 U.S.C. 1983, alleging that the judge had violated his right to keep and bear arms and his right to equal protection by denying his license application on the ground of his domicile. The district court granted the judge summary judgment. Upon Appellant's appeal, the Second Circuit Court of Appeals certified a question to the N.Y. Court of Appeals. The Court answered by holding that an applicant who owns a part-time residence in New York but makes his permanent domicile elsewhere is eligible for a New York handgun license in the city or county where his part-time residence is located. View "Osterweil v. Bartlett" on Justia Law