Justia Civil Rights Opinion Summaries

After a jury trial, Defendant was convicted of the offense of manslaughter. The Appellate Division affirmed. At issue on appeal was whether Defendant's trial counsel was ineffective for failing to use a peremptory challenge to remove a juror who was a long-time friend of the prosecuting attorney. The Court of Appeals affirmed, holding that counsel's decision not to use a peremptory challenge on the juror was questionable, but the mistake, if it was one, was not the sort of egregious and prejudicial error that rendered counsel's representation of Defendant as a whole ineffective, and thus, Defendant was not deprived of his constitutional right to counsel. View "People v. Thompson" on Justia Law

Defendant, a patient in the psychiatric ward of a medical center, was convicted of assault in the first and second degree based on an incident in which he assaulted and severely injured another psychiatric patient. The Appellate Division modified by vacating the second degree assault conviction and, as modified, affirmed. The Court of Appeals affirmed, holding that Supreme Court did not deny Defendant his constitutional right to present a defense, to confront witnesses, and to a fair trial by limiting Defendant's examination of two witnesses - a doctor who evaluated Defendant after the assault and the assault victim's father. View "People v. Daryl H." on Justia Law

After a jury trial, Defendant was convicted of intentional murder and second-degree weapon possession. On appeal, Defendant argued that the trial judge committed mode of proceedings errors by departing from the protocol for handling jury notes set forth in People v. O'Rama. The Appellate Division affirmed the conviction and sentence, determining that Defendant's unpreserved claims did not implicate O'Rama or constitute mode of proceedings errors and declining to reach them in the interest of justice. The Court of Appeals affirmed, holding that Defendant's claims were unpreserved and unreviewable and did not constitute mode of proceedings errors. View "People v. Alcide" on Justia Law

In these two unrelated cases, Defendants were resentenced because the sentencing court failed to impose mandatory postrelease supervision (PRS) as part of the original sentence. Defendants appealed, concluding that the imposition of PRS to their determinate sentences at resentencing violated Double Jeopardy Clause. The Appellate Division affirmed the resentences, concluding that Defendants did not have a legitimate expectation of finality in their respective determinate sentences because they had not completed their aggregated sentences prior to resentencing. The Court of Appeals affirmed, holding that Defendants' respective resentences did not violate the Double Jeopardy Clause because Defendants did not have a legitimate expectation of finality until they had completed their aggregated sentences under N.Y. Penal Law 70.30. View "People v. Brinson" on Justia Law

Defendant was convicted of burglary in the first degree and robbery in the second degree. Defendant appealed, arguing that his arrest was illegal, and therefore, his subsequent lineup identification as the perpetrator of the crime was the fruit of an illegal arrest. The Appellate Division affirmed, holding (1) the officer who arrested Defendant lacked probable cause to stop and arrest Defendant; but (2) an "intervening event" attenuated the causal connection between the illegal arrest and the lineup identification. The Court of Appeals affirmed, holding (1) the initial arrest of Defendant was without probable cause and therefore illegal; but (2) at the time of the lineup identification, any taint of the illegal arrest had been attenuated. View "People v. Jones" on Justia Law

Defendant was charged with second-degree assault based on a confrontation with Complainant. After a Sandoval hearing, the People received permission to cross-examine Defendant about his recent rape conviction, still pending on direct appeal. Defendant was convicted of third-degree assault. Subsequently, Defendants conviction for rape was reversed, and he was retried and acquitted. The Appellate Division affirmed the assault conviction, holding that the Sandoval issue was unpreserved for appellate review. The Court of Appeals reversed and ordered a new trial, holding (1) the Sandoval issue was properly preserved; (2) the prosecution may not cross-examine about the underlying facts of an unrelated criminal conviction on appeal for the purpose of impeaching his credibility; and (3) accordingly, the trial court's ruling allowing admission of the underlying facts of Defendant's rape conviction was in error, as it violated Defendant's privilege against self incrimination. View "People v. Cantave" on Justia Law

After a jury trial, Defendant was convicted of depraved indifference murder of a child and manslaughter in the first degree. The appellate division affirmed. The Court of Appeals affirmed, holding (1) a rational jury could have found beyond a reasonable doubt that Defendant's state of mind during the crime was one of utter indifference to the value of human life, and therefore, the evidence was sufficient to support Defendant's conviction of depraved indifference murder; (2) the evidence was sufficient to prove that Defendant consciously disregarded the substantial and unjustifiable risk that death or serious injury would result from his actions; (3) the evidence of first-degree manslaughter was sufficient; and (4) Defendant's counsel offered effective assistance. View "People v. Barboni" on Justia Law

After a jury trial, Defendant was convicted of criminal possession in the second degree. Defendant appealed the denial of his motion to suppress the weapon obtained during a search, arguing that the manner in which a police officer conducted the inventory search of Defendant's vehicle was improper, and thus, the entire search was invalid. The Court of Appeals affirmed, holding that the People met their burden of establishing a valid inventory search of Defendant's vehicle, as (1) the search was in accordance with procedure; (2) the search was not made invalid when the officer conducting the search did not follow the written police procedure by giving some of the contents of the vehicle to a third party without itemizing that property; and (3) the fact that the officer searched in the vehicle's seat panels, knowing that contraband is often hidden by criminals in such places, did not invalidate the search because the officer's intention was to search for items to inventory. View "People v. Padilla " on Justia Law

After a jury trial, Defendant was convicted of murder in the second degree and sentenced to twenty-five years to life. Defendant moved to vacate the conviction, arguing that his trial counsel was ineffective for, among several other things, failing to obtain Defendant's psychiatric records. Supreme Court denied the motion. The Appellate Division reversed the denial of the motion to vacate and remanded for a new trial, holding that trial counsel's failure to obtain and review Defendant's psychiatric records deprived Defendant of effective representation. The Court of Appeals affirmed, holding that trial counsel's failure to obtain and review Defendant's psychiatric records and to pursue a strategy informed by both the available evidence and Defendant's concerns seriously compromised Defendant's right to a fair trial. View "People v. Oliveras" on Justia Law

Defendant was charged with sex-related crimes. In his summation, defense counsel argued that parts of Complainant's testimony were incredible because a statement Complainant gave to a police officer who responded to her 911 call omitted a number of details that were in Complainant's later testimony and that the People should have called the officer to testify. The trial court directed the jury to disregard counsel's missing witness argument. After summations, defense counsel moved for a mistrial on the basis of this ruling. The court denied the motion, stating that counsel should have asked for a missing witness instruction if he wanted to make a missing witness argument. Defendant was then convicted of criminal sexual act, criminal contempt, and assault. The Appellate Division affirmed, concluding that there was no "good faith basis" for comment by defense counsel on the People's failure to call the officer. The Court of Appeals affirmed, holding that the trial court erred in prohibiting Defendant from making a missing witness argument but that the error was harmless. View "People v. Thomas" on Justia Law