Justia Civil Rights Opinion Summaries

In this personal injury case, the Court of Appeals affirmed the order of the Appellate Division reversing Supreme Court's denial of Defendant's motion for summary judgment, holding that the requisite showing of minimum contacts with New York was lacking.Plaintiffs commenced this personal injury action against several defendants, including the defendant at issue in this appeal, an Ohio firearm merchant who sold a gun to an Ohio resident in Ohio that was subsequently resold on the black market and used in a shooting in New York. Defendant moved for summary judgment, asserting a defense of lack of personal jurisdiction. Supreme Court denied the motion. The Appellate Division reversed and dismissed the complaint as against Defendant. The Court of Appeals affirmed, holding that, in the absence of minimum contacts, New York courts may not exercise personal jurisdiction over Defendant. View "Williams v. Beemiller, Inc." on Justia Law

The Court of Appeals reversed the judgment of the Appellate Division upholding Defendant's conviction of six counts of first-degree robbery, holding that the trial court created a specter of bias when it negotiated and entered into a cooperation agreement with a codefendant requiring the codefendant to testify against Defendant in exchange for a more favorable sentence.During Defendant's trial, the codefendant testified for the People, admitting to his own involvement in the robbery and identifying Defendant as his accomplice. Defendant moved to preclude the codefendant's testimony, arguing that the cooperation agreement between between the trial court and the codefendant indicated that the court had abdicated its responsibility to act in a neutral and detached manner. The trial court denied Defendant's motion, and Defendant was convicted. The Appellate Division upheld the judgment of conviction. The Court of Appeals reversed, holding that the trial court abandoned the role of a neutral arbiter and assumed the function of an interested party, thus denying Defendant his due process right to a fair trial in a fair tribunal. View "People v. Towns" on Justia Law

The Court of Appeals affirmed the decision of the Appellate Division affirming Defendant's conviction of attempted assault in the first degree, holding that a portion of a testifying witness's prior grand jury testimony was properly admitted as a past recollection recorded to supplement his trial testimony.The Appellate Division held that the trial court properly exercised its discretion in admitting the grand jury testimony as a past recollection recorded because the People laid a proper foundation for the admission of the testimony and that there was no violation of the Confrontation Clause because the witness testified at trial and was subject to cross-examination. The Court of Appeals affirmed, holding that there was a proper foundation for receipt of the evidence and that Defendant's Sixth Amendment right to confrontation was not violated. View "People v. Tapia" on Justia Law

The Court of Appeals affirmed the decision of the Appellate Division denying Defendant's petition for a writ of error coram nobis based on Appellant's claim that he received ineffective assistance of counsel, holding that Appellant was provided with meaningful representation under the State's ineffective assistance of counsel standard.In his petition, Appellant argued that he was deprived of the effective assistance of appellate counsel due to (1) counsel's failure to challenge his sentences as unduly harsh and severe, and (2) deficiencies in the quality of the appellate brief and appellate counsel's communication with Appellant. The Appellate Division denied Appellant's application. The Court of Appeals affirmed, holding (1) Appellant was afforded meaningful representation on his direct appeal, and therefore, Appellant's counsel was not ineffective under the New York State Constitution; and (2) because the New York meaningful representation standard offers greater protection than the federal test, Appellant's federal constitutional challenge is rejected as well. View "People v. Alvarez" on Justia Law

The Court of Appeals held that a correctional facility’s release to prosecutors or law enforcement agencies of recordings of nonprivileged telephone calls made by pretrial detainees, who are notified that their calls will be monitored and recorded, does not violate the Fourth Amendment.Defendant was charged with multiple offenses and committed the custody of the New York City Department of Correction. At trial, the prosecution sought to introduce excerpts of four phone calls Defendant made from prison recorded by DOC containing incriminating statements. Supreme Court admitted the recordings into evidence. The Appellate Division affirmed, concluding that the DOC’s failure to notify Defendant that the recordings of his calls may be turned over to prosecutors did not render the calls inadmissible. The Court of Appeals affirmed, holding (1) detainees, who are informed of the monitoring and recording of their calls, have no objectively reasonable constitutional expectation of privacy in the content of those calls; and (2) therefore, a correctional facility does not violate the Fourth Amendment when it records and monitors detainees’ calls and then shares the recordings with law enforcement officials and prosecutors. View "People v. Diaz" on Justia Law

In this Freedom of Information Law (FOIL) dispute, the Court of Appeals held that police officer personnel records are exempt from disclosure pursuant to N.Y. Pub. Off. Law 87(2)(a) and N.Y. Civ. Rights Law 50-a.The New York Civil Liberties Union (NYCLU) commenced this N.Y. C.P.L.R. 78 proceeding seeking disclosure of protected personnel records from the New York City Police Department (NYPD) pursuant to FOIL. Supreme Court ordered the NYPD to disclose redacted records. The Appellate Division reversed, holding that controlling precedent determined that the NYPD could not be ordered to disclose redacted versions of the records. The Court of Appeals affirmed, holding that N.Y. Pub. Off. Law 87(2)(a) and N.Y. Civ. Rights Law 50-a mandate confidentiality and supply no authority to compel redacted disclosure. View "New York Civil Liberties Union v. New York City Police Department" on Justia Law

The Court of Appeals reversed the order of the Appellate Division and directed that a new trial be ordered in this case involving a noncitizen charged with a crime carrying the penalty of deportation, holding (1) a noncitizen defendant who demonstrates that a charged crime carries the potential penalty of deportation is entitled to a jury trial under the Sixth Amendment; and (2) the trial court’s refusal to grant Defendant’s request for a jury trial violated his Sixth Amendment right.Defendant, a noncitizen, was charged with deportable offenses and submitted a motion asserting his right to a jury trial. Supreme Court denied the motion and found Defendant guilty. The Appellate Division affirmed, holding that deportation is a collateral consequence arising out of federal law that does not constitute a criminal penalty for purposes of the Sixth Amendment right to a jury trial. The Court of Appeals reversed, holding (1) collateral consequences attendant to deportation are not categorically excluded form Sixth Amendment protection; (2) the Sixth Amendment mandates a jury trial in the rare situation where a legislature attaches a sufficiently onerous penalty to an offense, whether the penalty is imposed by the state or national legislature; and (3) because Defendant’s offense was a serious one, Defendant was entitled to a jury trial. View "People v. Suazo" on Justia Law

The Court of Appeals affirmed the decision of the Appellate Division affirming the judgment of Supreme Court granting Defendants' motion to compel Plaintiff to post a minimum of $500 security in this personal injury action, holding that N.Y. C.P.L.R. 8501(a) and 8503 do not violate the Privileges and Immunities Clause set forth in article IV, section 2 of the United States Constitution by depriving noncitizens of New York reasonable and adequate access to New York courts.At issue in this personal injury action was New York’s longstanding security for costs provisions that treat resident and nonresident litigants differently. Plaintiff was a New York resident when she commenced this action, but after she relocated to Georgia, Defendants moved, pursuant to sections 8501(a) and 8503, for an order compelling Plaintiff to post a minimum of $500 security for costs in the event she lost the case. Supreme Court granted Defendants’ motion, concluding that the statutes do not bar access to the courts. The Appellate Division affirmed. The Court of Appeals affirmed, holding that sections 8501(a) and 8503 do not unduly burden nonresidents’ fundamental right to access the courts because nonresidents are provided reasonable and adequate access to the New York courts. View "Clement v. Durban" on Justia Law

The Court of Appeals held that a defendant is not entitled to a writ of error coram nobis to bypass the limitation set by the legislature in N.Y. Crim. Proc. Law 460.30 in which to file a criminal leave application (CLA) seeking leave to appeal to this Court.This case followed the decision of In People v. Andrews, 23 N.Y.3d 605, 616 (2014), in which the Court of Appeals concluded that counsel’s failure to timely file a CLA to the Court of Appeals within the thirty-day statutory timeframe or move pursuant to CPL 460.30 within the one-year grace period for an extension to cure the error does not constitute ineffective assistance or deprive the defendant of due process. In this case, the Court of Appeals held that because there is no state constitutional right to legal representation on an application for leave to appeal to this Court, Defendant could not seek relief in coram nobis to negate the one-year time limitation on the remedy provided in CPL 460.30 for his attorney’s failure to file a timely CLA where there was no constitutional violation. View "People v. Grimes" on Justia Law

At issue was whether Family Court can find that the New York City Administration for Children’s Services (ACS) made “reasonable efforts” toward family reunifications, as required by N.Y. Fam. Ct. 1089, if ACS failed to provide the “reasonable accommodations” required by the Americans with Disabilities Act (ADA).Mother, an intellectually disabled individual, moved Family Court for a determination that ACS had not made reasonable efforts to reunite her with her child because ACS had not complied with the ADA by ensuring that she had access to certain services. Family Court responded by requiring ACS to provide the services Mother claimed as “reasonable accommodations” under the ADA. ACS generally provided those services. The Appellate Division determined that ACS had made reasonable efforts to provide Mother with services to facilitate the permanency goal of “return to parent.” The Court of Appeals affirmed, holding that the record supported the Family Court’s conclusion that ACS’s efforts met a minimum threshold of reasonableness. View "In re Lacee L." on Justia Law