Justia Constitutional Law Opinion Summaries

In 2008, defendant was charged with attempted rape and was represented by his first attorney. Defendant retained his second attorney, Long, in 2009. Long represented defendant throughout a significant portion of the pre- and post-indictment proceedings, including plea negotiations and a Huntley hearing. In September 2009, defendant fired Long and retained a third attorney, who represented him for the remainder of the prosecution. Defendant was convicted and subsequently made successive CPL 440.10 motions to vacate the conviction based on newly discovered evidence relating to the credibility of witnesses. The Appellate Division affirmed the conviction and the denial of both CPL 440 motions. In 2014, defendant moved to vacate his conviction pursuant to CPL 440.10, asserting that attorney Long had simultaneously represented the Albany County District Attorney Soares, that evidence of the conflict was newly discovered, that his conviction was obtained in violation of his right to counsel, that the conviction was based on misrepresentation or fraud by the prosecutor, and that Long had provided ineffective assistance. Four months before defendant retained Long, Long had written a letter in connection with Soares' reelection campaign, asking the Board of Elections asking to examine the machine ballots. In 2011-2012, Long was counsel of record for Soares in a disciplinary proceeding and in Soares' divorce. County Court denied the motion without a hearing. The Appellate Division and New York Court of Appeals affirmed, determining that there was no support for the assertion that there was an actual conflict and that defendant failed to show that any potential conflict had operated on the defense. View "People v Wright" on Justia Law

In Matter of Maron v. Silver, the Supreme Court concluded that the Legislature’s and Governor’s practice of directly and explicitly tying consideration of judicial compensation to unrelated policy initiatives - called linkage - during years 2006 through 2008 violated the separation of powers doctrine. As a result of the Court’s decision, the Legislature passed, and the Governor signed, legislation establishing the Independent Commission on Judicial Compensation, by which the issue of judicial compensation now receives consideration independent of other political matters. In the instant case, Plaintiffs, current and retired judges and justices, sought an award of money damages to remedy the constitutional violation that led to the court’s decision in Matter of Maron. The Appellate Division denied relief. The Court of Appeals affirmed, holding that neither Matter of Maron nor any other authority permitted the Court to grant monetary relief to Plaintiffs in this case. View "Larabee v. Governor of State of N.Y." on Justia Law

After a trial, Defendant was convicted of criminal possession of a weapon in the second degree and menacing in the second degree. Defendant appealed, arguing that the trial court violated his constitutional right to confront the witnesses against him by permitting the People to introduce DNA reports into evidence providing that Defendant’s DNA profile was found on the gun that was the subject of the charged possessory weapon offense without producing a single witness who conducted, witnessed, or supervised the laboratory’s generation of the DNA profile from the gun or Defendant’s exemplar. The Appellate Division affirmed. The Court of Appeals reversed and ordered a new trial, concluding that an analyst who witnessed, performed or supervised the generation of Defendant’s DNA profile, or who used his or her independent analysis on the raw data, must be available to testify. View "People v. John" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree and related crimes. Defendant appealed, arguing that the trial court erred in precluding him from presenting third-party culpability evidence. The Appellate Division affirmed. The Court of Appeals affirmed, holding (1) the standard set forth in People v. Primo that third-party culpability evidence should be evaluated in accordance with ordinary evidentiary principles does not infringe upon a defendant’s constitutional right to present a complete defense; and (2) applying the Primo standard in this case, the trial court did not abuse its discretion by precluding Defendant’s “ill-defined and speculative” third-party culpability evidence. View "People v. Powell" on Justia Law

In 2013, the New York State Office of Parks, Recreation and Historic Preservation (OPRHP) announced the adoption of a regulation prohibiting smoking in each state park located in New York City, as well as other designated areas under the jurisdiction of OPRHP. NYC C.L.A.S.H., Inc. (CLASH), a nonprofit organization dedicating to protecting the interests of smokers, commenced this hybrid N.Y. C.P.L.R. 78 proceeding and declaratory judgment action challenging the rule as unconstitutional and in violation of the separation of powers doctrine. Supreme Court granted the petition, concluding that the rule violated the separation of powers doctrine. The Appellate Division reversed. The Court of Appeals affirmed, holding that OPRHP and its commissioner acted within the confines of OPRHP's legislatively delegated power and did not usurp the authority of the legislature by promulgating the regulation at issue. View "NYC C.L.A.S.H., Inc. v. State Office of Parks, Recreation & Historic Pres." on Justia Law

Defendant was charged with murder. Defendant filed a motion to suppress his initial statement made to a police detective, as well as a statement he made after a forty-five-minute break, on the grounds that the detective failed to issue a complete set of Miranda warnings at the outset of the interview. The hearing court granted the motion to suppress. The Appellate Division reversed and denied the suppression motion, concluding that Defendant’s second statement had been attenuated from the first. After a trial, the jury returned a verdict convicting Defendant of murder in the second degree. Defendant moved to vacate the judgment, alleging that defense counsel had provided ineffective assistance by failing to move to reopen the suppression hearing based on the detective’s trial account of the statement made by Defendant prior to the issuance of the Miranda warnings. Supreme Court denied Defendant’s post-judgment motion without a hearing. The Appellate Division affirmed. The Court of Appeals affirmed, holding that counsel had a reasonable trial strategy, and therefore, Defendant was not entitled to relief on his ineffective assistance claim. View "People v. Gray" on Justia Law

Defendant was found guilty of murder in the second degree, attempted murder in the second degree, and related charges. The Appellate Division reversed the judgment and ordered a new trial. At the second trial, a witness that had been unavailable at the first trial testified for the prosecution. When asked if he was at the scene of the shooting, the witness invoked his Fifth Amendment privilege against self-incrimination. Defendant appealed, arguing that the witness’s invocation of his Fifth Amendment privilege added “critical weight” to the People’s case, that the witness’s testimony deprived him of a fair trial, and that the trial court erred in allowing the People to impeach the witness with his prior inconsistent statements. The Appellate Division affirmed. The Court of Appeals affirmed, holding (1) the prosecution did not exploit the witness’s invocation of his Fifth Amendment privilege, and therefore, the witness was properly called; (2) the trial court did not err in allowing the People to introduce the witness’s prior statement for the limited purpose of impeaching him; and (3) the trial court did not err in precluding Defendant's identification expert from testifying about the effect of stress on the accuracy of an identification. View "People v. Berry" on Justia Law

After a joint trial, Defendant was found guilty of robbery in the second degree, petit larceny, menacing in the second degree, and possession or use of an imitation pistol or revolver. Defendant appealed, arguing that the trial court erred in admitting a non-testifying codefendant’s grand jury testimony under Bruton v. United States because the statements were facially incriminating as to Defendant. The Appellate Division agreed with Defendant and reversed the judgment and remanded for a new trial. The Court of Appeals affirmed, holding that the trial court’s admission of the codefendant’s statements, which were incriminating as to Defendant in the constitutional sense, was error, and the error was not harmless. View "People v. Johnson" on Justia Law

After a jury trial, Defendant was convicted of first-degree gang assault and fourth-degree weapons possession and sentenced to an aggregate term of sixteen years in prison. Defendant appealed, arguing that the admission of a nontestifying codefendant’s redacted statement to law enforcement officers violated Defendant’s rights under the Confrontation Clause of the Sixth Amendment. The Appellate Division affirmed. The Court of Appeals reversed, holding that because the redacted statement was facially incriminating, the admission of the statement violated Defendant’s rights under the Confrontation Clause, as discussed in Bruton v. United States, and the error was not harmless. View "People v. Cedeno" on Justia Law

After a jury trial, Defendant was convicted of burglary in the first degree. The Appellate Division affirmed. The Court of Appeals affirmed, holding (1) the trial court did not commit a mode of proceedings error when it allowed prospective jurors to opt out of serving on the jury due to hardship; (2) the trial court did not err in precluding third-party culpability evidence proferred by the defense; and (3) Defendant was not deprived of the effective assistance of counsel due to trial counsel’s failure to object to certain inflammatory statements made by the prosecutor during summation. View "People v. King" on Justia Law