Justia Civil Rights Opinion Summaries

Defendant was arrested for robbery. An attorney from the Legal Aid Society represented Defendant at trial. Prior to opening statements, defense counsel alerted the court to a possible conflict of interest arising from counsel's previous representation of Franklin DeJesus, whom it was rumored to have committed the robbery. After internal discussions with the trial judge, defense counsel proceeded with the case. The jury found Defendant guilty of first-degree robbery. After Defendant's conviction, Legal Aid moved to set aside the verdict based on newly discovered evidence consisting of DeJesus' alleged jailhouse confession to Defendant. Supreme Court denied the motion. The Appellate Division affirmed, determining that Defendant had not been deprived of his right to effective legal assistnce due to Legal Aid's dual representation of Defendant and DeJesus because there was no conflict between their interests. The Court of Appeals affirmed, holding that Defendant did not adequately demonstrate that he received less than meaningful representation, as the record did not establish that the potential conflict actually affected the presentation of the defense or otherwise impaired counsel's performance. View "People v. Sanchez" on Justia Law

Defendant was charged with intentional murder and second-degree weapon possession. Defendant's first trial resulted in a hung jury and mistrial. Defendant was re-tried, and the jury convicted Defendant as charged. After the jury verdict was handed down, the presiding judge, Justice Carter, issued an order recusing himself because of his discovery that he knew the uncle of the victim. In the meantime, Defendant filed a motion seeking an order granting his prior applications for a trial order of dismissal. Justice Palmieri, the judge to whom the case was reassigned, denied Defendant's motion. Defendant appealed, arguing that the evidence was legally insufficient to prove his guilt and that N.Y. Judiciary Law 21 barred any other judge than Justice Carter from deciding his motion. The Appellate Division affirmed. The Court of Appeals affirmed, holding (1) legally sufficient evidence supported Defendant's convictions; and (2) Judiciary Law 21 did not bar Justice Palmieri from ruling on the motion at issue. View "People v. Hampton" on Justia Law

After a trial, Defendant was convicted of murder in the second degree. Defendant appealed, challenging his custodial interrogation that lasted almost fifty hours. Defendant's previously filed motion to suppress was granted to the extent of excluding the statements Defendant made during the "marathon interrogation." On appeal, Defendant argued that his suppression motion should have been granted not only to the statements made during the interrogation itself but to the further extent of suppressing his subsequent inculpatory statements. The appellate division held that Defendant's subsequent statements, which were made approximately ten hours after the lengthy interrogation were sufficiently attenuated from the prior interrogation to conclude that they were not the product of official compulsion. The Court of Appeals reversed and ordered a new trial, holding that, as a matter of law, the taint of the wrongful police action was not attenuated. View "People v. Guilford" on Justia Law

The Empire Zones Program Act offered state tax incentives designed to enhance business development in the state. In 2009, the program was amended to introduce two new criteria businesses must meet to retain their certificates for the program. Plaintiffs were five businesses which were certified under the program prior to 2008. In 2009, Plaintiffs were decertified from the program for failing to meet the new criteria. Supreme Court granted summary judgment for the James Square plaintiffs, concluding that the state defendants acted without legal authority when they applied the new criteria for the program retroactively. The legislature subsequently clarified its intention, stating that the 2009 amendments to the program were to be applied retroactively to January 1, 2008. Supreme Court adhered to its prior determination, declaring that the legislature's clarification as applied was unconstitutional. The Appellate Division affirmed. Regarding the additional plaintiffs, the Appellate Division modified Supreme Court's holding to the extent of granting Plaintiff's petitions seeking a declaration that the 2009 amendments could not be applied retroactively to January 1, 2008. The State appealed. The Court of Appeals affirmed the Appellate Division's determinations in all five cases that the 2009 amendments should not be applied retroactively. View "James Square Assocs. LP v. Mullen" on Justia Law

Defendant was charged by felony complaint with numerous crimes relating to Defendant's procurement of loans to purchase properties using the personal identifying information of four mortgage loan applicants. Defendant waived his right to be prosecuted by indictment and pleaded guilty under a superior court information (SCI) to one count of grand larceny in the first degree and one count of scheme to defraud in the first degree. The appellate division vacated Defendant's plea, concluding that the SCI was jurisdictionally defective because it named victims not identified in the felony complaint. The Court of Appeals reversed, holding that the SCI served as a proper jurisdictional predicate for Defendant's guilty plea and was not defective. View "People v. Milton" on Justia Law

Defendants were convicted of conspiracy in the second degree and criminal possession of a controlled substance in the first degree for their respective roles in a drug-trafficking operation involving the movement of 400 pounds of cocaine from California to New York. The appellate division affirmed. Defendants appealed, arguing, among other things, that the trial court erred when it did not conduct an in-camera inquiry of a juror, who, prior to deliberations, wrote a note asking a question about the case. Defendants claimed that the use of the word "we" in the note implied that at least two of the jurors had been engaged in premature deliberations. The Court of Appeals affirmed, holding (1) absent some indication that the note-writing juror had engaged in some disqualifying conduct, the fact that one or more jurors may have engaged in premature deliberations or requested additional evidence was not sufficient to trigger a Buford inquiry; and (2) the remainder of Defendant's arguments were without merit. View "People v. Mejias" on Justia Law

After a jury trial, Defendant was convicted of one count of murder in the second degree. After retaining a new attorney for his appeal, Defendant moved to set aside the verdict, arguing that his trial counsel was ineffective. County Court denied the motion without a hearing. The Appellate Division affirmed the conviction, finding that, although trial counsel's representation may have been "unorthodox," it was not ineffective. The Court of Appeals reversed after noting that defense counsel's actions throughout this case showed an unfamiliarity with or disregard for basic criminal procedural and evidentiary law. The Court held that while defense counsel's errors in this case individually may not constitute ineffective assistance, the cumulative effect of counsel's actions deprived Defendant of meaningful representation. View "People v. Oathout" on Justia Law

Respondent was an inmate in the custody of the State Department of Corrections and Correctional Services (DOCCS). In 2010, Respondent undertook a month-long hunger strike, contending that he had ceased eating in order to secure transfer to another DOCCS facility and to bring attention to certain claims of mistreatment. After Respondent had lost 11.6 percent of his body weight, DOCCS commenced this proceeding requesting a court order permitting medical personnel to insert a nasogastric tube and take other reasonable steps necessary to provide hydration and nutrition to Respondent. Supreme Court granted DOCCS' motion. Respondent subsequently resumed eating solid food but nevertheless appealed. The Appellate Division concluded the case was moot except for the issue of whether the State violated Respondent's rights by securing the force-feeding order. On that issue, the Appellate Division ruled in favor of DOCCS, concluding that the force-feeding order did not violate Respondent's right to refuse medical treatment. The Court of Appeals affirmed, holding that Respondent's rights were not violated by the judicial order permitting the State to feed him by nasogastric tube after his health devolved to the point that his condition became life-threatening. View "Bezio v. Dorsey" on Justia Law

Defendant pleaded guilty to attempted first-degree robbery pursuant to a plea agreement. Defendant subsequently moved to withdraw his guilty plea, alleging, among other things, that the sentence promise was deficient because the judge did not explain to him at the time of the plea that a violation of post release supervision could result in his being incarcerated for up to five additional years of imprisonment, "over and above the ten years promised by the court." The county court denied the motion, and the appellate division affirmed. The Court of Appeals affirmed, holding the ramifications of a defendant's violations of the conditions of postrelease supervision are collateral consequences of a criminal conviction, are speculative at the time of the guilty plea, and are not a core component of the sentence imposed on the defendant by the judge. View "People v. Monk" on Justia Law

This appeal involved three defendants, who were charged with multiple counts of criminal sale of a controlled substance. In each case, the trial court concluded that the courtroom should be closed to the general public during the testimony of two undercover officers on the ground that closure was necessary to protect the officers' safety and ongoing investigations. After jury trials, Defendants were convicted as charged. At issue on appeal was whether the trial court properly closed the courtroom to the general public during the testimony of the undercover officers. The Court of Appeals held that the limited closures comported with Sixth Amendment public trial principles but that a new trial was required in one case based on an erroneous jury charge on the agency defense. View "People v. Echevarria" on Justia Law