Justia Civil Rights Opinion Summaries

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

After a jury trial, Defendant, an accountant, was convicted of one count of second-degree larceny and several counts second-degree criminal possession of a forged instrument (CPFI), forty of which related to checks Defendant endorsed in a client's (Client) name. Defendant appealed, arguing that because the power of attorney Client executed granting Defendant powers to act in her stead with respect to a long list of subjects vested Defendant with the legal right to sign Client's name on the checks, his act in doing so was not forgery. The appellate division reversed Defendant's forty check-related CPFI convictions and dismissed those counts of the indictment, concluding that the evidence was not legally sufficient to convict Defendant of those crimes. The Court of Appeals affirmed, holding that because Defendant was empowered to sign Client's name at the times when he drew or endorsed the forty checks at issue, there was legally insufficient evidence to convict him of CPFI. View "People v. Ippolito" on Justia Law

Upon Defendant's arraignment on charges of attempted robbery and robbery, the Legal Aid Society was assigned as Defendant's counsel. The Legal Aid Society later requested an adjournment date that would allow for a new Legal Aid attorney to prepare for trial, which the trial court rejected. The court then relieved the Legal Aid Society and assigned new counsel. Defendant pleaded guilty to robbery in the first degree and attempted robbery in the second degree. The appellate division reversed the conviction, concluding that the trial court's discharge of Defendant's counsel without consulting Defendant was an abuse of discretion and interfered with Defendant's right to counsel. The Court of Appeals affirmed, holding (1) Defendant did not forfeit his Sixth Amendment claim by pleading guilty; and (2) the trial court abused its discretion when it removed the Legal Aid Society. View "People v. Griffin" on Justia Law

Defendant was indicted for second-degree kidnapping, two counts of second-degree weapon possession, and first-degree reckless endangerment. Defendant pled guilty to the charges. On appeal, Defendant sought reversal of the kidnapping conviction, arguing that his restraint of the victim was incidental to the conduct constituting reckless endangerment, and therefore, the kidnapping count merged with the reckless endangerment offense. The Appellate Division declined to address the merger theory since Defendant's guilty plea forfeited this claim. The Court of Appeals affirmed, holding that the preservation rule, which states that any claims of error not preserved by appropriate objection in the court of first instance will not be considered by the Court of Appeals, applies to a merger claim in a kidnapping prosecution, and therefore, Defendant's failure to assert the claim in Supreme Court precluded the Court's review. View "People v. Hanley" on Justia Law

Defendant was charged with assaulting three deputy sheriffs while he was an inmate in county jail. At trial, Defendant testified that one deputy, Saeva, had started the physical fight. Defendant also denied kicking at or trying to hurt another deputy, Schliff. The jury acquitted Defendant of assaulting two of the deputies, including Saeva, but convicted him of assaulting Schliff. At issue was a video camera located in the cell block where Defendant and Saeva had their altercation. The video images were destroyed by the State before trial. At trial, the court refused to give an adverse inference charge as to the count on which Defendant was convicted with respect to any video of the incident because Defendant had asked for the preservation of that video before it was destroyed. The Court of Appeals reversed and ordered a new trial, holding that Defendant was entitled to have an adverse inference charge given as to all counts. View "People v. Handy" on Justia Law