Justia Civil Rights Opinion Summaries

At issue in this appeal was whether the judge of the county court (Respondent) exceeded his authority when he disqualified the county district attorney (Petitioner) and his staff from prosecuting a case against Defendants and appointed a special attorney to pursue the case. The underlying case stemmed from an investigation initiated by Petitioner and other agencies relating to the illegal sale of steroids and other prescription drugs over the internet. After Defendants were indicted, they commenced a civil action against Petitioner and his staff, alleging that their federal constitutional rights had been violated during the prosecution of the criminal case. Respondent subsequently disqualified Petitioner from further prosecution of the matter, reasoning that the pending civil law suit against Petitioner and his staff created a conflict of interest sufficient to warrant dismissal of the indictment. Thereafter, Petitioner commenced a proceeding pursuant to N.Y. C.P.L.R. 78 seeking to prohibit enforcement of Respondent's orders. The appellate division granted the petition and vacated the orders. The Court of Appeals affirmed, holding that Respondent exceeded his statutory authority by disqualifying Petitioner from the underlying matter and that the appellate division's decision to exercise its discretion in issuing the writ of prohibition was appropriate. View "Soares v. County Count (Herrick)" on Justia Law

Defendant was convicted of murder, attempted murder, assault, and weapons offenses. The theory of the defense at trial was that the real killer was not Defendant, but the leader of Defendant's gang, Simeon Nelson. Defense counsel attempted to interview Nelson before trial, and the prosecutor tried to use that effort to the People's advantage during the People's summation. The appellate division affirmed. Twelve years later, Defendant moved to set aside his conviction, arguing that the prosecutor had accused defense counsel of trying to fabricate a defense, with the result that Defendant was deprived of his right to conflict-free counsel. The county court denied the motion. Defendant then began the present coram nobis proceeding, arguing that appellate counsel was at fault for failing to argue, on appeal, that the conduct of the prosecutor at trial subjected Defendant's trial lawyers to ethical conflicts and thereby deprived Defendant of the effective assistance of trial counsel. The appellate division denied coram nobis relief. The Court of Appeals affirmed, holding that Defendant failed to demonstrate that his appellate counsel was ineffective. View "People v. Townsley" on Justia Law

Respondent was convicted of attempted rape in the first degree. A trial was later held pursuant to N.Y. Mental Hyg. Law, article 10, after which a jury found that Respondent was a detained sex offender who suffered from a mental abnormality within the meaning of that statute. At a later hearing, Supreme Court, acting without a jury, concluded that clear and convincing evidence in the record established that Respondent was a dangerous sex offender requiring confinement, and committed him to a secure facility. Respondent appealed, and the Appellate Division affirmed. The Court of Appeals affirmed, holding (1) the State did not violate Respondent's rights under the Equal Protection Clause of the Federal and State Constitutions; and (2) Respondent was not denied his state constitutional right to trial by jury. View "State v. Myron P." on Justia Law

Defendant was convicted of manslaughter in the first degree. In a statement given shortly after the homicide, and at trial, Defendant admitted fatally stabbing her estranged boyfriend but claimed she had done so while attempting to defend herself. The trial evidence showed that Defendant had been a frequent victim of sexual and other physical abuse since her early childhood. After a social worker testified that Defendant had stabbed another man in the thigh and that Defendant was "very angry toward men" for all the abuse she had suffered, the prosecutor argued that the fatal stabbing had been motivated by anger and not by a reasonably perceived need to resort to deadly force for self-protection. Defendant's principal appellate contention was that the social worker's testimony should not have been received. The appellate division affirmed. The Court of Appeals reversed and ordered a new trial, holding that the evidence was not demonstrably relevant to the specific state of mind at issue in this case and was more prejudicial than probative. View "People v. Bradley" on Justia Law

Defendant was charged with endangering the welfare of a child. During the court of Defendant's bench trial, the trial court restrained Defendant without articulating a specific justification for doing so. Defendant was convicted of the charge. The Appellate Court upheld the conviction, rejecting Defendant's claim that the trial court erred in ordering that he remain handcuffed during the proceedings. The Court of Appeals affirmed the conviction, holding (1) the rule governing visible restraints in jury trials applies with equal force to non-jury trials, and the district court erred in failing to state a basis on the record for keeping Defendant handcuffed throughout these proceedings; but (2) based upon the Court's recent holding in People v. Clyde, the constitutional error committed here was harmless. View "People v. Best" on Justia Law

Having decided to arrest Defendant for driving with a revoked license, a police officer also decided to impound the car he was driving. The officer did not inquire whether Defendant's passenger, who was not the registered owner of the car, was licensed and authorized to drive it. Defendant pled guilty for criminal possession of a weapon in the second degree. Defendant appealed, arguing that the officer acted unreasonably when he decided to impound and search the car without inquiring whether the passenger was licensed and authorized to drive it. The Supreme Court affirmed the conviction, holding (1) no such inquiry was constitutionally required; and (2) the officer's search of the car after he decided to impound it was a valid inventory search. View "People v. Walker" on Justia Law

The lawyer who represented Defendant at a pre-trial hearing and at trial was simultaneously representing, in an unrelated matter, a police officer who testified for the People that Defendant had confessed to one of the charged crimes. Defendant appealed, contending that his lawyer's conflict denied him the effective assistance of counsel. The appellate division affirmed Defendant's convictions, holding (1) Defendant's waiver of any conflict of interest was invalid, but (2) Defendant failed to establish that any conflict affected the conduct of the defense. The Court of Appeals reversed and ordered a new trial, holding that, because there was no valid waiver of the lawyer's conflict of interest, Defendant was entitled to a new trial. View "People v. Solomon" on Justia Law

The question presented by these consolidated appeals was whether a defendant must preserve the argument that he was deprived of the right to a public trial when his family members were excluded from the courtroom during a portion of voir dire. In People v. Alvarez, the appellate division rejected Alvarez's argument that he had been deprived of a public trial as unpreserved and, in any event, without merit. In People v. George, the appellate division found George's argument that his right to a public trial had been violated was unpreserved and, in any event, without merit. The Court of Appeals (1) affirmed in George, as preservation is required; and (2) reversed in Alvarez and remitted for a new trial, as the issue was adequately preserved. View "People v. Alvarez" on Justia Law

Defendant contested his second violent felony offender adjudication, predicated upon a prior conviction in Pennsylvania that occurred when he was eighteen years old, contending (1) because he could have been accorded youthful offender status had he committed that crime in New York, he was entitled to such status for the purpose of enhanced sentencing, and (2) N.Y. Penal Law 70.04(1)(b)(v)'s tolling provision violated the equal protection clause of the State Constitution. The Court of Appeals affirmed, holding (1) because Defendant did not receive youthful offender treatment for the underlying offense at issue, he was not now entitled to a retroactive application of youthful offender status to a foreign felony conviction; and (2) section 70.04(1)(b)(v)'s tolling provision, as applied to persons with differing years of incarceration may result in disparate punishment, does not violate the equal protection clause. View "People v. Meckwood" on Justia Law

At Defendant's trial for second-degree murder, the trial judge agreed with the defense attorney that a reasonable view of the evidence supported his request to submit the lesser-included offenses of first- and second-degree manslaughter to the jury. But contrary to defense counsel's request and repeated statements that, in his professional judgment, the lesser-included offenses should be given to the jury, the judge did not do so because Defendant objected. The jury found Defendant guilty of murder. The appellate division affirmed. The Court of Appeals reversed and ordered a new trial, holding (1) the trial judge denied Defendant the expert judgment of counsel guaranteed by the Sixth Amendment, as the decision regarding whether to instruct the jury on lesser-included offenses is for the defense attorney, not the accused, to make; and (2) the error was not harmless beyond a reasonable doubt. View "People v. Colville" on Justia Law