Justia Civil Rights Opinion Summaries

Supreme Court convicted Defendant of three crimes of terrorism under N.Y. Penal Law 490.25 premised on first-degree manslaughter, attempted second-degree murder and second-degree weapon possession, as well as second-degree conspiracy for agreeing to commit first-degree gang assault as a crime of terrorism. The Appellate Division modified by reducing the terrorism convictions to the three primary offenses, holding that the People established that Defendant only engaged in gang-related street crimes, not terrorist acts. Both parties appealed. On the People's appeal, the Court of Appeals affirmed, holding that the evidence in this case was insufficient to establish Defendant's guilt beyond a reasonable doubt under Penal Law 490.25, as Defendant's criminal acts as a member of a gang were not acts of terrorism under the statute. On Defendant's cross-appeal, the Court of Appeals reversed, holding that Defendant was entitled to a new trial on the underlying offenses specified in the terrorism counts because the theory of terrorism should not have been charged, and the People were therefore permitted to introduce otherwise inadmissible evidence that unduly prejudiced the jury's ability to fairly adjudicate Defendant's guilt or innocence. View "People v. Morales" on Justia Law

Plaintiffs were owners of real property in the Town of Chester (Town), New York. Plaintiffs then lived in New Jersey, and their address there appeared on the deed. Plaintiffs subsequently moved without informing the Town taxing authorities of their new address. After Plaintiffs failed to pay taxes on their New York property for three years, Plaintiffs defaulted in a foreclosure proceeding brought by the County on their New York property. The property was later sold. Plaintiffs subsequently sued the County, asserting that the attempts to give them notice of the foreclosure were constitutionally inadequate and seeking a declaration that they still owned the property. Supreme Court granted the County's motion for summary judgment, and the Appellate Division affirmed. The Court of Appeals affirmed, holding (1) when notice mail to Plaintiffs at their last known address proved undeliverable, the tax collector was not constitutionally required to find some means of making personal service on them, or to address a notice to "occupant" at the former address, or to search New Jersey public records for a new address; and (2) therefore, Plaintiffs were not deprived of their property without due process of law. View "Naughton v. Warren County" on Justia Law

Defendant took an undercover police officer to meet a drug dealer, handled the cocaine transaction for the officer, and then gave him the drugs. For these acts, Defendant was charged with selling cocaine, facilitating the sale, and possessing narcotics. At trial, Defendant claimed he was not guilty of the sale or facilitation counts because he was acting as the agent of the buyer. The trial court acquitted Defendant of the sale under an agency theory but convicted him of facilitation and possession. At issue on appeal was whether a claim of agency may be interposed as a defense to the crime of facilitating a drug sale. The Court of Appeals affirmed, holding (1) based on the plain language of the facilitation statutes and the historic rationale underlying the agency doctrine, agency may not be interposed as a defense to a charge of criminal facilitation; and (2) therefore, Defendant was properly convicted of that offense. View "People v. Watson" on Justia Law

Defendant was arrested and charged with two counts of driving while intoxicated and operating a vehicle with a backseat passenger under sixteen years of age without a seatbelt. Defendant moved to suppress her statements made prior to her arrest. The justice court found the evidence before the arresting officers was insufficient to establish probable cause to arrest Defendant and accordingly dismissed the charges. The appellate term affirmed the dismissal. The Court of Appeals affirmed, holding (1) both the justice court and the appellate term applied the correct standard of proof in deciding the question of probable cause for arrest; and (2) further review on the issue of probable cause for arrest was precluded. View "People v. Vandover" on Justia Law

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