Justia Civil Rights Opinion Summaries

In the case of People v. Ramirez, Fernando Ramirez, the defendant, was convicted of causing a three-car collision while intoxicated, resulting in one death and four serious injuries. During the trial, which took place amidst the COVID-19 pandemic, safety protocols such as social distancing and mask-wearing were implemented. The defendant objected to these measures, claiming they impeded his ability to fully observe the facial expressions of prospective jurors, thereby infringing on his rights to be present at all material stages of his trial and to meaningfully contribute to his defense. The New York Court of Appeals disagreed, stating that neither a defendant's right to be present during jury selection nor due process requires that a defendant have a simultaneous, unobstructed view of the entirety of every prospective juror's face during jury selection. The Court affirmed that the safety protocols did not violate the defendant's right to be present and observe the jury selection process, and there was no violation of due process.The defendant also requested a mistrial after observing the deceased victim's surviving spouse crying in the courtroom. He argued that this could induce undue sympathy from the jury. However, the trial court denied the motion, as the crying was not conspicuous and there was no indication the jury was aware of it. The court further offered a curative instruction to prevent sympathy, which the defense counsel declined. The New York Court of Appeals upheld the trial court's decision, affirming that there were no grounds for a mistrial. View "People v Ramirez" on Justia Law

The case involves Clifton Park Apartments, LLC and its attorney (collectively referred to as "Pine Ridge"), CityVision Services, Inc. ("CityVision"), and the New York State Division of Human Rights ("DHR"). CityVision is a Texas-based not-for-profit corporation that tests whether housing facilities engage in discrimination. In 2016, CityVision placed a test call to Pine Ridge and subsequently filed a discrimination complaint with DHR, alleging familial status discrimination. DHR dismissed the complaint due to lack of probable cause. Following this, Pine Ridge's attorney sent a letter to CityVision stating that Pine Ridge considered the allegations in CityVision's complaint to be "false, fraudulent, and libelous" and threatened to seek damages. In response, CityVision filed a second complaint with DHR, alleging that Pine Ridge retaliated against them for filing the first discrimination complaint.The Appellate Division annulled DHR's determination of retaliation and the case was brought before the Court of Appeals of New York. The Court of Appeals held that a threat of litigation could constitute the requisite adverse action to support a retaliation claim under New York State Human Rights Law. In this case, DHR rationally concluded that the element of adverse action had been established when Pine Ridge sent the threatening letter to CityVision. However, the Court also held that a remittal was necessary because DHR improperly shifted the burden when analyzing whether CityVision had engaged in protected activity. The Court of Appeals ruled that DHR should have determined whether CityVision reasonably believed that Pine Ridge had engaged in a discriminatory practice during the test call. Consequently, the judgment was reversed, and the matter remitted to the Appellate Division with directions to remand to DHR for further proceedings. View "Clifton Park Apts., LLC v New York State Division of Human Rights" on Justia Law

The Court of Appeals reversed the judgment of the appellate division affirming Defendant's conviction on two counts of murder in the second degree and one count of robbery in the second degree, holding that the warrantless entry into Defendant's home was not based on consent, and therefore, the suppression court erred in denying Defendant's motion to suppress.Defendant was indicted on several charges including kidnapping, robbery, and felony murder. Defendant filed a motion to suppress, arguing that the warrantless, nonconsensual entry into his home was unlawful. The suppression court denied the motion. The appellate division affirmed. The Court of Appeals reversed, holding that the warrantless entry into the apartment in which Defendant was found by police officers and arrested violated Defendant's rights under the New York and United States Constitutions. View "People v. Cuencas" on Justia Law

The Court of Appeals reversed the order of the appellate division affirming Defendant's conviction, holding Supreme Court should have suppressed a gun as the product of an impermissible stop because the police officers lacked reasonable suspicion of criminal activity or probable cause that Defendant had violated the rules of the road while riding his bicycle.Defendant was riding his bicycle down a road when police officers drove alongside him and asked him to stop. Defendant stopped and, in response to an officer's question, admitted that he was carrying a gun. Defendant pleaded guilty to a weapons charge. The appellate division affirmed. The Court of Appeals reversed, holding (1) police interference with a bicyclist is a seizure requiring reasonable suspicion of a criminal offense or probable cause of a Vehicle and Traffic Law violation; and (2) the officers in this case violated the New York and United States Constitutions when they stopped Defendant, and therefore, the indictment against Defendant must be dismissed. View "People v. Rodriguez" on Justia Law

The Court of Appeals reversed Defendant's conviction for one count of criminal possession of a weapon in the second degree, holding that the record did not support the trial court's conclusion that Defendant was not in custody for purposes of Miranda v. Arizona, 384 US 436 (1966), when he was handcuffed and questioned by law enforcement officers.On appeal, Defendant argued that Supreme Court erred in denying his motion to suppress statements he made to police while handcuffed and the physical evidence found in his vehicle because the officers failed to read him his Miranda rights prior to questioning him and because he never voluntarily consented to a search of the vehicle. The Court of Appeals reversed Defendant's conviction, holding (1) Defendant was in custody and had not received Miranda warnings when he answered questions by the police officers and therefore, Supreme Court erred in denying Defendant's motion to suppress his responses to the officers' questions; and (2) the Miranda violation when Defendant was stopped and handcuffed did not render his later written consent to search his vehicle involuntary. View "People v. Cabrera" on Justia Law

The Court of Appeals affirmed Defendant's convictions of two counts of murder in the first degree and two counts of murder in the second degree, holding that the admission of two autopsy reports through an expert witness who did not perform the autopsies, combined with that witness's testimony, violated Defendant's constitutional right to confrontation, but the error was harmless.Defendant was convicted of murdering the two young children in her care by repeatedly stabbing them. The Court of Appeals affirmed the convictions, holding (1) People v. Freycinet, 11 NY3d 38 (NY 2008), should no longer be followed because it is inconsistent with the demands of the Confrontation Clause as recently articulated by the Supreme Court; and (2) Defendant's constitutional right to confrontation was violated by the admission of the autopsy reports and the testimony of the witness at issue, but the error was harmless beyond a reasonable doubt. View "People v. Ortega" on Justia Law

The Court of Appeals reversed the decision of the appellate division affirming Defendant's convictions for second degree robbery and petit larceny, holding that admission of a criminalist's testimony and underlying exhibits was error, and the error was not harmless, thus entitling Defendant to a new trial.On appeal, the appellate division ruled that Defendant's constitutional right to confrontation was not violated when the criminalist performed his own analysis about the creation of DNA profiles. The Court of Appeals disagreed and reversed, holding that because the record failed to establish that the testifying analyst had the requisite involvement with the DNA profiles the admission of the criminalist's testimony and underlying exhibits was erroneous, and the People did not establish that there was no reasonable possibility that the error might have contributed to Defendant's conviction. View "People v. Jordan" on Justia Law

The Court of Appeals affirmed the order of the appellate division affirming the judgment of Supreme Court denying Defendant's motion to suppress the firearm found in the vehicle he was driving, holding that the People sustained their burden of demonstrating that the inventory search protocol in this case met "the constitutional minimum."Two New York Police Department officers observed Defendant commit multiple traffic infractions while driving, stopped him, and arrested him for carrying a gravity knife in his pocket. At the precinct, the officers conducted an inventory search of the vehicle and recovered a firearm from the truck. Defendant filed a motion to suppress the firearm on the grounds that the NYPD's inventory search protocol was unconstitutional. The motion was denied, and Defendant pled guilty to criminal possession of a firearm. The Court of Appeals affirmed, holding that Defendant failed to overcome the People's proof establishing a valid inventory search protocol. View "People v. Douglas" on Justia Law

The Court of Appeals affirmed the order of the appellate division reversing Supreme Court's conclusion that the application of the Sexual Assault Reform Act (SARA) to Petitioner violated the Ex Post Facto Clause of the federal Constitution when applied to offenders whose crimes predated the 2005 amendments to the Act, holding that the effect of SARA's school grounds condition, as codified in N.Y. Exec. Law 259-c(14), was not punitive.In 1986, Petitioner was convicted of two counts of murder in the second degree and other crimes. Petitioner was unable to locate SARA-compliant housing before his open release date and therefore remained in custody until he could locate suitable housing under SARA's school grounds condition prohibiting him from living within 1,000 feet of a school. Petitioner filed a petition for a writ of habeas corpus arguing that SARA's residency restriction violated ex post facto principles. Supreme Court granted Petitioner's application and ordered his release. The appellate division reversed. The Court of Appeals affirmed, holding that the condition does not violate the Ex Post Facto Clause. View "People ex rel. Rivera v. Superintendent, Woodbourne Correctional Facility" on Justia Law

The Court of Appeals reversed the conclusion of the appellate division that the Sex Offender Registration Act (SORA) court acted within its discretion by upwardly departing to level three in determining Defendant's risk level classification, holding that the SORA court deprived Defendant of basic due process protections of notice and an opportunity to be heard.Defendant's convictions required him to register under SORA. At the SORA hearing, the court noted that Defendant would normally be required to register as a level two sex offender but upwardly departed to level three due to Defendant's "extensive prior disciplinary history." The appellate division affirmed. The Court of Appeals reversed, holding that the proceeding failed to comport with due process because Defendant was provided no notice or meaningful opportunity to be heard in response to the District Attorney's request for an upward departure. View "People v. Worley" on Justia Law