Justia Constitutional Law Opinion Summaries

The case involves a dispute over the adjusted Medicaid reimbursement rates for for-profit residential health care facilities in New York. The New York State Department of Health and its Commissioner, in response to a legislative mandate, eliminated a component known as the "residual equity reimbursement factor" from the computation formula used to set these rates. This change was part of a broader effort to reduce Medicaid costs in the state. The petitioners, 116 for-profit nursing homes, challenged this adjustment, arguing that it was retroactively applied and violated their rights under the Public Health Law and the Equal Protection Clause.The Supreme Court partially granted the petitioners' motion for a preliminary injunction against enforcement of the clause pending a final determination of the proceeding. It also partially granted the respondents' motion for summary judgment, dismissing the petitioners' claims that the adjusted rates were not "reasonable and adequate to meet costs" under the Public Health Law and violated their equal protection rights. However, the court found that the adjusted rates were improperly applied retroactively. The Appellate Division affirmed the Supreme Court's decision.The New York Court of Appeals, in its review, held that the Department of Health did not violate the legislature's intent when it announced the recalculated rates for services provided on or after April 2, 2020. The court found that the legislature clearly expressed its intent for the elimination clause to be applied without delay, and that the initial implementing ratemaking was not subject to the usual 60-day advance notice requirement. The court also rejected the petitioners' claims that the adjusted rates were not "reasonable and adequate to meet costs" and violated their equal protection rights. The court modified the order of the Appellate Division in accordance with its opinion and, as so modified, affirmed it. View "In re Aaron Manor Rehabilitation & Nursing Ctr., LLC v Zucker" on Justia Law

The case revolves around Corey Dunton, who was convicted of attempted murder, assault, criminal possession of a weapon, and reckless endangerment after he opened fire at a skating rink, injuring two individuals. Dunton had a history of violent outbursts and disruptive behavior, both in and out of the courtroom. During the announcement of the verdict, Dunton, who was handcuffed for security reasons, disrupted the proceedings with verbal outbursts directed at the jury. As a result, the court ordered his removal from the courtroom.The Appellate Division, First Department, affirmed Dunton's conviction. However, following a similar case (People v Antoine), Dunton's appellate counsel contacted the Office of the Appellate Defender (OAD) regarding filing a writ of error coram nobis on Dunton's behalf. The OAD filed the writ, arguing that appellate counsel was ineffective for failing to raise certain claims, including that the trial court violated Dunton's constitutional and statutory right to be present during the rendering of the verdict when it removed him from the courtroom without prior warning. The Appellate Division granted the writ, reversed the judgment, and ordered a new trial.The case was then brought before the Court of Appeals. The court held that the trial court's removal of Dunton from the courtroom was appropriate given his history of violent outbursts and disruptive behavior. The court rejected the argument that any error was de minimis based on the timing of Dunton's removal from the courtroom. The court also held that the Appellate Division erroneously concluded that the trial court violated Dunton's right to be present, and therefore incorrectly granted Dunton's writ of error coram nobis on the sole ground that appellate counsel was ineffective for failing to raise this meritless claim on direct appeal. The court reversed the order of the Appellate Division and remitted the case to the Appellate Division for consideration of issues raised but not determined by that Court. View "People v. Dunton" on Justia Law

The case involves the Walt Disney Company and International Business Machines Corporation (IBM), both multinational corporations, and their dispute with the Tax Appeals Tribunal of the State of New York. The corporations challenged the state's taxation scheme that was in effect from 2003 to 2013. The scheme allowed corporations that paid franchise taxes in New York to deduct income received as royalty payments from members of the same corporate group in calculating their taxable income. The deduction was only allowed if the royalty payment came from a related entity that had already paid a New York tax on the same income. The state Department of Taxation and Finance determined that both corporations improperly deducted royalty payments they received from affiliates in foreign countries that were not subject to New York franchise taxes. The corporations argued that the denial of the deduction was contrary to the statute and violated the Commerce Clause's prohibition on discrimination against foreign commerce.The corporations challenged the denial of their royalty tax deductions and the notices of deficiency with the New York State Division of Tax Appeals. The Administrative Law Judges (ALJs) determined that the deduction authorized under the law only applied where the royalty came from a subsidiary that had been subjected to the add back requirement contained in the law. The ALJs denied the petitions and sustained the notices of deficiency. The Tax Appeals Tribunal subsequently affirmed both decisions. The corporations then commenced proceedings in the Appellate Division, which affirmed the determinations and dismissed the petitions. The corporations appealed to the Court of Appeals.The Court of Appeals affirmed the decisions of the lower courts. The court held that the Appellate Division correctly interpreted the statutes as permitting a tax deduction only where a related subsidiary was subject to the add back requirement. The court also found that any burden on interstate or foreign commerce created by this tax scheme was incidental and did not violate the dormant Commerce Clause. The court rejected the corporations' argument that the tax scheme was facially discriminatory against out-of-state commerce and failed the internal consistency test. The court concluded that the tax scheme treated groups with related members who did not pay taxes in New York the same as those with related members who did, and that the scheme did not result in duplicative taxation in all situations. View "In re Walt Disney Company and Consolidated Subsidiaries v Tax Appeals Tribunal" on Justia Law

In the case of a sex offender diagnosed with severe schizophrenia and psychosis, the New York Court of Appeals held that due process does not require a competency examination before a sex offender's risk level can be determined under the Sex Offender Registration Act (SORA). The defendant, who was found not mentally fit to stand trial, argued that his risk classification hearing should have been adjourned until he was deemed competent to understand the proceedings. The court disagreed, stating the numerous safeguards already provided under SORA, including the rights to notice, counsel, disclosure of relevant information, and an opportunity to object and present evidence at a hearing, adequately balance the interests involved. The court also rejected the defendant's argument that the classification hearing was premature under SORA itself, holding that SORA authorizes risk-level determinations "[30] calendar days prior" to a registrant's release from incarceration, regardless of pending civil commitment proceedings. The court affirmed the lower court's decision to designate the defendant as a level two (moderate risk) sex offender. View "People v Watts" on Justia Law

In a dispute involving a fatal stabbing outside a Manhattan bar in 2000, defendant Gonzalo Aguilar appealed his conviction of murder in the second degree, attempted murder in the second degree, and assault in the first degree. Aguilar asserted that the trial court erred by not including a reinstruction on the justification defense in its response to a jury note, and that the court's interested witness charge violated his constitutional right to due process.The Court of Appeals of the State of New York disagreed with Aguilar's claims. The court held that the trial court's response to the jury's note was meaningful and appropriate. It reasoned that the jury's note had specifically requested the definitions of the charges, not a reinstruction on the justification defense. Furthermore, the court noted that the trial court was in the best position to evaluate the jury's request and had significant discretion in determining the scope and nature of its response. The court also pointed out that the jury did not seek further instruction or clarification after the recharge, indicating that the trial court's response was satisfactory.In addition, the court found that Aguilar's argument concerning the interested witness charge was unpreserved as it had not been raised in the trial court and no exception to the preservation rule applied in this case. Thus, the court affirmed the decision of the Appellate Division. View "People v Aguilar" on Justia Law

In New York, a man named Joshua Messano was indicted for second-degree criminal possession of a weapon after police officers discovered a loaded handgun in his car. Messano moved to suppress this evidence, arguing that it was found as a result of an unlawful detention and search. The police had initially detained Messano on suspicion of a drug transaction based on their observations of him engaging in a conversation with another man in an empty parking lot. They did not, however, observe any actual exchange of drugs. After detaining Messano, the police saw what they believed to be drug-related contraband in plain view on the driver's seat of his car, which led them to search the car and find the gun.The Court of Appeals of New York reversed the lower court's decision, holding that the police did not have reasonable suspicion to detain Messano based on their observations. The court also held that the drug-related contraband was not in plain view, as the officer only saw it after unlawfully detaining Messano. Therefore, the court concluded that the seizure of the gun was unconstitutional and the evidence should be suppressed. The indictment against Messano was dismissed. View "People v Messano" on Justia Law

In 2017, two police officers observed Devon T. Butler, the appellant, engage in what they believed was a hand-to-hand drug transaction. After observing Butler fail to stop at a stop sign, the officers initiated a traffic stop. When Butler stepped out of his vehicle, the officers noticed a bulge in his pants, which Butler claimed was $1,000 in cash. When Butler refused the officers' request to search his vehicle, an officer used a Belgian Malinois, a narcotics-detection dog, to sniff-test the vehicle for drugs. The canine sniffed Butler's body, indicated the presence of narcotics, and the officers arrested Butler after a pursuit. The officers found a bag containing 76 glassine envelopes of heroin, which Butler admitted belonged to him. Butler moved to suppress evidence of the drugs, arguing that the officers' use of the canine to search his vehicle and person was unlawful. Following a hearing, the County Court denied the motion.On December 19, 2023, the New York Court of Appeals held that the use of a narcotics-detection dog to sniff a defendant's body for evidence of a crime is considered a search and thus falls under the protections of the Fourth Amendment. The court reversed the lower court's decision and remitted the case back to the County Court for further proceedings. The court ruled that the Appellate Division erred in affirming the judgement based on a ground not decided adversely to the defendant by the suppression court. The court also expressed uncertainty on whether the County Court's conclusion that the defendant "abandoned" the narcotics was based on its holding that the canine sniff was not a search and was "perfectly acceptable." As a result, the case was remitted back to the County Court for further proceedings and consideration of whether the abandonment of narcotics was lawful or unlawful. View "People v Butler" on Justia Law

The New York Court of Appeals held that the New York State Independent Redistricting Commission (IRC) failed to fulfill its constitutional duties for redistricting maps after the 2020 census. The court affirmed a lower court decision ordering the IRC to reconvene and deliver a second set of lawful redistricting maps.In 2014, New York voters amended the state constitution to mandate that the IRC, not the courts or the legislature, draw legislative districts. However, the IRC failed to deliver the required maps, resulting in a court-ordered redistricting plan for the 2022 elections.The court clarified that such court-directed plans are limited to the "extent" that the court is "required" to do so, and are not meant to last longer than necessary to remedy a violation of law. Therefore, the existing court-drawn districts are limited to the 2022 election.The court dismissed arguments that it was too late to compel the IRC to act, explaining that the court-ordered maps were not required to last a decade and that the IRC's constitutional obligation could be enforced at any time, unless barred by laches. The court also rejected arguments that the lawsuit was a collateral attack on an earlier decision, which dealt with a different issue.The ruling orders the IRC to submit a second set of redistricting maps and implementing legislation to the legislature as soon as possible, but no later than February 28, 2024. View "Matter of Hoffmann v New York State Ind. Redistricting Commn." 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