Justia Constitutional Law Opinion Summaries

The case concerns a defendant who was convicted of multiple serious offenses, including two counts of first-degree murder, following a shooting in Rochester, New York, that resulted in two deaths and one victim being paralyzed. The investigation linked the defendant to the crime through eyewitness identifications and forensic evidence, such as shell casings and fingerprints on a handgun magazine. After the incident, police located and arrested the defendant at an apartment where he had stayed overnight. A subsequent search of the apartment, conducted with the tenant’s consent, yielded a 9-millimeter handgun hidden in a toilet tank, which was later used as evidence against the defendant.After his conviction in Monroe County, the defendant moved to suppress the handgun, arguing that his arrest was unconstitutional under Payton v. New York because police coerced him to exit the apartment without a warrant, and that the tenant’s consent to search was not voluntary or sufficiently attenuated from the unlawful arrest. The Supreme Court denied suppression, finding no Payton violation, concluding the defendant lacked standing, and determining the consent was voluntary. The Appellate Division, Fourth Department, found a Payton violation due to the coercive nature of the arrest but held that suppression was not warranted because the tenant’s consent was voluntary and attenuated from the illegality.The New York Court of Appeals reviewed the case and affirmed the Appellate Division’s conclusion that there was a Payton violation, based on overwhelming police force and coercion. The Court clarified that both the Fourth Amendment and New York Constitution prohibit such constructive entries. However, it found that the Appellate Division applied the wrong legal standard to assess voluntariness of the tenant’s consent, confusing voluntariness with attenuation. The Court of Appeals remitted the case for the Appellate Division to apply the correct standard regarding the handgun as to count nine, while holding any error was harmless on the remaining counts. The order was thus modified and otherwise affirmed. View "People v Shaw" on Justia Law

After being stopped by police while driving with his teenage daughter as a passenger, the defendant admitted to consuming alcohol and marijuana. He failed several field sobriety tests, and a drug recognition expert concluded that he was impaired by the combination of alcohol and cannabis, rendering him unable to safely operate the vehicle. The prosecution presented an indictment to the grand jury for aggravated driving while ability impaired by a combination of drugs and alcohol, with a child in the vehicle, as defined in the Vehicle and Traffic Law.The Monroe County Court granted the defendant’s request to use the impairment standard from People v Caden N., which equated impairment from drugs or drugs and alcohol with the higher threshold for intoxication. Since the grand jury had not been instructed under this standard, the County Court dismissed the primary count of the indictment. The Appellate Division, Fourth Department, reversed and reinstated the charge, holding that the Cruz definition of impairment should apply consistently to all subdivisions of the statute, including those involving drugs or a combination of drugs and alcohol. The court reasoned that the statutory text and legislative history supported a single definition of “impaired,” distinct from “intoxicated,” and rejected the rationale of Caden N.The New York Court of Appeals reviewed the case. It held that the term “impaired” in Vehicle and Traffic Law § 1192 should be defined as affecting a driver’s abilities “to any extent,” consistent with the standard established in People v Cruz, regardless of whether the impairment stems from alcohol, drugs, or their combination. The Court affirmed the Appellate Division’s order, rejecting the Caden N. approach and confirming that “impaired” has a uniform meaning throughout the statute. View "People v Dondorfer" on Justia Law

Petitioners are owners and residents of units in SoHo and NoHo buildings designated under New York City’s Joint Living-Work Quarters for Artists (JLWQA) program, which, since 1971, has limited legal occupancy to certified artists or those who obtained amnesty through later amendments. In 2021, the City rezoned the area, allowing JLWQA units to be voluntarily converted to unrestricted residential use upon payment of a one-time fee calculated by square footage. The fee supports an arts fund. Petitioners challenged this fee, claiming it was an unconstitutional condition and a taking under the Fifth Amendment.The case was first heard in New York Supreme Court, which dismissed the petition, finding that the fee was a monetary obligation not subject to the Takings Clause. The Appellate Division, First Department, reversed, holding that the fee was a permit condition subject to heightened scrutiny under the Nollan and Dolan unconstitutional conditions doctrine. The court found that the City failed to show the fee had an essential nexus to a legitimate governmental interest or was roughly proportional to any harm caused by conversion, declared the fee unconstitutional, and enjoined its enforcement.The New York Court of Appeals reviewed the case and reversed the Appellate Division’s order. The Court of Appeals held that petitioners did not have a compensable property interest within the meaning of the Takings Clause regarding the opportunity to convert their JLWQA units. The fee did not constitute a taking because it did not diminish or extinguish existing property rights, nor was it imposed in lieu of a direct appropriation of property. The Court further clarified that a standalone monetary fee for conversion does not implicate the Takings Clause and that heightened scrutiny under Nollan/Dolan only applies to direct exactions or in-lieu-of-property conditions. Judgment was granted for the City. View "Matter of Coalition for Fairness in Soho & Noho, Inc. v City of New York" on Justia Law

The defendant pleaded guilty to one count of sexual misconduct, a conviction that triggers registration requirements under the Sex Offender Registration Act (SORA). At the time of his plea, he was not notified of these obligations, and neither the Board of Examiners of Sex Offenders nor the sentencing court took the steps required by statute to initiate SORA registration. Approximately five years passed before the Board became aware of his conviction. During this period, the defendant remained unregistered and worked at a facility for juveniles. Once the oversight was discovered, a full SORA proceeding was conducted, resulting in his classification as a level one sex offender, which carries the least restrictive requirements and a twenty-year registration period ordered nunc pro tunc from the date of his release.After the SORA hearing, the defendant moved to dismiss the proceedings, arguing that the delay violated his substantive due process rights, and alternatively sought to be designated an unclassified offender. The Supreme Court denied these requests but reduced his risk level from two to one after declining to assess points for release without supervision based on his conduct during the delay. The Appellate Division affirmed, noting that the delay did not prejudice the defendant and, in fact, benefited him by lowering his risk level.The New York Court of Appeals reviewed the case and held that a defendant must demonstrate prejudice to his ability to present his case at the SORA hearing to establish a substantive due process violation for delayed proceedings. Because the defendant did not suffer prejudice—instead, he received a less onerous classification due to the delay—the Court of Appeals concluded that the delay did not violate his substantive due process rights and affirmed the order of the Appellate Division. View "People v Collier" on Justia Law

The plaintiff was hired as a “Full Time Jewish Educator” at a religious institution and was responsible for teaching in religious classrooms, planning and attending religious events, and supporting the synagogue’s mission to develop a strong Jewish identity. Soon after starting her job, the plaintiff was confronted by a rabbi about her co-authorship of a blog post that was critical of Israel and Zionism. Although she assured the rabbi she would not share her personal views at work and was told her teaching abilities were not in question, she was terminated less than a week later.The plaintiff filed suit in New York Supreme Court, alleging that her dismissal violated Labor Law § 201-d(2)(c), which prohibits employers from taking adverse action against employees for engaging in legal recreational activities outside of work. The defendants moved to dismiss, arguing the claim failed because the activity was not protected, there was a material conflict with the employer’s interests, and the ministerial exception barred the claim. The Supreme Court granted the motion to dismiss, holding that the complaint failed to state a cause of action because the termination was for the content of the blog post, not the act of blogging itself, and did not address the other grounds for dismissal. The Appellate Division affirmed on the same basis and declined to reach the alternative arguments.The New York Court of Appeals affirmed the Appellate Division’s order, but on a different ground. The Court of Appeals held that, regardless of whether the plaintiff’s activity was protected under Labor Law § 201-d, the ministerial exception—which bars application of employment discrimination laws to the employment relationship between a religious institution and its ministers—applied. The plaintiff’s offer letter conclusively established that her core duties were religious in nature, and thus her claim was barred as a matter of law. View "Sander v. Westchester Reform Temple" on Justia Law

On July 30, 2022, police responded to Omar Johnson's home after a 911 call reported domestic violence. While investigating, officers discovered a loaded pistol in Johnson's moped and determined he did not possess a valid firearm license. Johnson was arrested and indicted for multiple counts of criminal weapon possession and possession of ammunition. These events occurred shortly after the U.S. Supreme Court issued its decision in New York State Rifle & Pistol Association, Inc. v. Bruen, but before New York amended its firearm licensing laws.Johnson moved to dismiss the indictment in the Supreme Court of New York County, arguing that Bruen invalidated the state's "proper cause" requirement for firearm licenses and, by extension, rendered the entire licensing scheme unconstitutional. The Supreme Court denied the motion, holding that Johnson lacked standing because he had not applied for a license and that Bruen invalidated only the "proper cause" requirement, not the entire scheme. Johnson pleaded guilty, waiving his right to appeal, and was sentenced to probation. On appeal, the Appellate Division, First Department, affirmed, concluding that the appeal waiver was valid, Johnson lacked standing, and his conviction was not unconstitutional under Bruen.The New York Court of Appeals reviewed the case. It held that Johnson’s facial constitutional challenge to the licensing scheme was not waived by his appeal waiver, as such claims implicate broader societal interests. The Court determined that Johnson had standing to raise a facial challenge, even though he never applied for a license, because his conviction directly resulted from the licensing scheme. On the merits, the Court concluded that Bruen’s invalidation of only the "proper cause" requirement did not render the entire New York firearm licensing scheme unconstitutional, as the requirement is severable. The order of the Appellate Division was affirmed. View "People v Johnson" on Justia Law

The defendant was charged with several offenses after a violent confrontation with a 20-year-old escort in his Queens home, leading to a police investigation that uncovered weapons, ammunition, forgery devices, and other items on the premises. During the jury trial, an alternate juror replaced a dismissed juror, leaving no further alternates. After the jury began deliberations, the foreperson reported an encounter outside his home with a man acting "on behalf of" the defendant, who provided court documents and claimed the defendant’s innocence. The foreperson, shaken by the incident, felt unable to remain impartial and was discharged from the jury.The Supreme Court, Queens County, held a hearing and found by clear and convincing evidence that the defendant orchestrated the confrontation with the foreperson, including feigning illness to leave court early. The court determined that this egregious misconduct was intended to improperly influence the jury. With no alternates available, the court, relying on forfeiture principles from prior cases, concluded the defendant forfeited his constitutional right to a jury of 12, and proceeded with 11 jurors. The 11-person jury found the defendant guilty on some counts and acquitted him on others.The Appellate Division affirmed the conviction, holding that the defendant’s "egregious" misconduct warranted forfeiture of the right to a 12-person jury. A dissenting Justice argued that such forfeiture should only occur in extreme circumstances, analogizing the right to a jury of 12 to the right to counsel. Upon review, the New York Court of Appeals held that a defendant who engages in egregious conduct affecting a sworn juror after deliberations begin, resulting in discharge and no alternates remaining, forfeits the right to a jury of 12. The court affirmed the trial court’s exercise of discretion in proceeding to verdict with 11 jurors. View "People v Sargeant" on Justia Law

Six residents of the Town of Newburgh sued the Town and its Town Board, alleging that the Board’s at-large electoral system unlawfully diluted the votes of Black and Hispanic residents, in violation of Section 17-206 of the New York Voting Rights Act (NYVRA). The plaintiffs argued that the method of electing all five Town Board members at-large prevented Black and Hispanic voters, who together made up about 40% of the population, from electing their preferred candidates or influencing election outcomes. They sought a court declaration that the at-large system violated the NYVRA and an injunction requiring the Town to implement a different electoral system.The Town of Newburgh moved for summary judgment, arguing that Section 17-206 was facially unconstitutional under the Equal Protection Clauses of the U.S. and New York Constitutions, and that its current election system complied with the NYVRA. The Supreme Court, Orange County, granted the Town’s motion, holding that the Town could challenge the statute because it allegedly could not comply with the NYVRA without violating equal protection, and declared the provision—and the entire NYVRA—unconstitutional. The Appellate Division reversed, holding that the Town lacked capacity to bring this challenge since it had not shown that compliance with the NYVRA would force it to violate equal protection, and that the Supreme Court erred in invalidating the statute.The New York Court of Appeals reviewed the case and held that the Town of Newburgh, as a political subdivision created by the State, could not bring a facial constitutional challenge to the NYVRA's vote-dilution provision. The court reaffirmed the longstanding rule that political subdivisions generally lack authority to challenge state laws unless a narrow exception applies, and found that no such exception was met here. The Appellate Division’s order was affirmed. View "Clarke v Town of Newburgh" on Justia Law

In 2023, the New York Legislature enacted the Even Year Election Law (EYEL), which consolidated certain county and town elections with even-year state and federal elections. The law amended various statutes to move local elections to even-numbered years and adjusted the terms of office for officials elected in odd-numbered years. Several counties and towns with charter provisions setting local elections in odd years, along with individual voters, challenged the EYEL, arguing that it violated the home rule provisions of article IX of the New York State Constitution and other constitutional rights.The Supreme Court, Onondaga County, consolidated the complaints and denied the defendants’ motions to dismiss. It declared the EYEL unconstitutional, holding that counties have a constitutional right to set their own terms of office and that the EYEL was neither a valid general law nor a valid special law under article IX. The court enjoined enforcement of the EYEL. On appeal, the Appellate Division reversed, finding that the EYEL did not violate the New York or United States Constitutions. The Appellate Division held that the EYEL was a general law, applied rationally to similarly situated counties, and served the legitimate state interest of increasing voter turnout.The New York Court of Appeals reviewed the case and affirmed the Appellate Division’s order. The Court held that article IX does not expressly or implicitly limit the Legislature’s authority to mandate the timing of local elections. The EYEL was found to be a valid general law, and the constitutional “bill of rights” for local governments did not bar the Legislature from enacting such a statute. The Court also dismissed the individual voter plaintiffs’ claims, finding any alleged injury minor compared to the State’s substantial interest. The order was affirmed without costs. View "County of Onondaga v State of New York" on Justia Law

The defendant, Laquawn Lewis, was charged with attempted murder, robbery, assault, and obstruction of governmental administration. Leading up to his trial, Lewis expressed dissatisfaction with his appointed counsel and filed various pro se motions. He eventually requested to represent himself, stating his intention to proceed pro se. The court denied his request without conducting the required inquiry into whether his decision was knowing, voluntary, and intelligent.At trial, Lewis reiterated his desire to represent himself, but the court again denied his request and proceeded with jury selection. Lewis later pleaded guilty to avoid a potential life sentence based on an incorrect assumption about his status as a persistent felony offender. After realizing the error, defense counsel moved to withdraw the guilty plea, which the court granted. Lewis renewed his request to represent himself, but the court deferred the decision until the trial date and ultimately denied it again. Lewis was convicted of all charges except attempted murder and sentenced to 25 years' incarceration and 5 years' post-release supervision.The Appellate Division affirmed the judgment, holding that Lewis's requests to proceed pro se were not unequivocal and that his legal sufficiency argument was unpreserved and without merit. A Judge of the Court of Appeals granted Lewis leave to appeal.The New York Court of Appeals concluded that the trial court violated Lewis's constitutional right to self-representation by denying his unequivocal request to proceed pro se without the requisite inquiry. The court held that Lewis's request was clear and timely, and the trial court's failure to conduct an inquiry warranted a new trial. The court also found that Lewis's legal sufficiency argument was unpreserved. Consequently, the Court of Appeals reversed the Appellate Division's order and granted Lewis a new trial. View "People v Lewis" on Justia Law