Justia Constitutional Law Opinion Summaries

Defendant struck and killed a pedestrian while driving an automobile and was subsequently transported to police headquarters. While Defendant’s attorney was pursuing telephone contact with law enforcement personnel, the police obtained Defendant’s consent to administer a breathalyzer test. After Defendant took the test, she was indicted for second-degree manslaughter, second-degree vehicular manslaughter, and two counts of driving while intoxicated. Defendant filed a motion to suppress the results of the breathalyzer test on the grounds that it had been administered in violation of her right to counsel. Supreme Court granted the motion and suppressed the chemical tests. The Appellate Division affirmed. The Court of Appeals affirmed, holding that the police violated Defendant’s constitutional right to counsel because Defendant was not alerted to the lawyer’s communication before the breath test occurred and because the People did not demonstrate that a notification of this nature would have been unreasonable under the circumstances. View "People v. Washington" on Justia Law

Petitioners were two medical providers whose patients included individuals insured by the State’s primary health benefit plan. The State Comptroller reviewed Petitioners’ billing records as part of an audit of billing practices in the health care industry for claims paid by the State. While Petitioners conceded that the State paid eighty percent of the costs of their services, Petitioners challenged the Comptroller’s authority to audit their books. Supreme Court concluded that the Comptroller lacked constitutional authority to audit Petitioners because Petitioners were “not a political subdivision of the State.” The Appellate Division modified Supreme Court’s orders to reinstate the audits. The Court of Appeals affirmed, holding that the State Constitution does not limit the Comptroller’s authority to audit, as part of its audit of State expenditures, the billing records of private companies that provide health care to beneficiaries of a State insurance program. View "Martin H. Handler, M.D., P.C. v. DiNapoli" on Justia Law

Petitioner sought disclosure under the Freedom of Information Law (FOIL) from the New York State Teachers’ Retirement System and the Teachers’ Retirement System of the City of New York (“retirement systems”) of the names of the retirement systems’ members. After the retirement systems refused to provide the names, Petitioner brought N.Y. C.P.L.R. 78 proceedings to compel disclosure. Supreme Court dismissed the petitions, and the Appellate Division affirmed. The Court of Appeals reversed, holding that N.Y. Pub. Off. Law 89(7) exempts from disclosure under FOIL only the home addresses, not the names, of retirees who receive benefits from public employees’ retirement systems. View "Empire Ctr. for N.Y. State Policy v. N.Y. State Teachers' Ret. Sys." on Justia Law

Defendant and his codefendants were charged via a sixty-one count indictment with several crimes arising from a sophisticated scheme to steal property through the use of forged credit cards. The case proceeded to trial on twenty-six of the counts. The jury found Defendant guilty on twenty of the twenty-six counts. Defendant appealed, arguing (1) the trial court ran afoul of N.Y. Crim. Proc. Law 310.20(2) when it submitted to the jury a verdict sheet containing the locations of the designated offenses; and (2) law enforcement’s warrantless installation of a GPS tracking device on Defendant’s vehicle violated this Court’s holding in People v. Weaver and the holding of the U.S. Supreme Court in United States v. Jones. The Court of Appeals affirmed, holding (1) the trial court appropriately included the annotations on the verdict sheet so that the jury could distinguish the submitted counts; and (2) Defendant’s constitutional rights were violated by the warrantless installation of the GPS tracking device on his vehicle, but the violation was harmless beyond a reasonable doubt. View "People v. Lewis" on Justia Law

These four cases involved criminal appeals that were not pursued for more than a decade after the filing of a notice of appeal. The Appellate Division dismissed the appeal in each case. The Court of Appeals (1) affirmed the dismissals in three of the cases, as the procedure followed in these cases did not deny the defendants of any constitutional right, nor did the Appellate Division abuse its discretion in dismissing the appeals; and (2) remitted the fourth case to the Appellate Division so that counsel could be appointed to represent the defendant in opposing the dismissal of his appeal, as the Appellate Division erred in denying this defendant’s appeal before assigning him counsel on that appeal and giving counsel a chance to review the record. View "People v. Perez" on Justia Law

Appellants retained Mary Dorman to represent them in a lawsuit. During the litigation, Dorman and Appellants entered into three separate retainer agreements pertaining to Dorman’s work on the trial, on the appeal to the Appellate Division, and on the appeal to the Court of Appeals. A jury ruled in Appellants’ favor, awarding them $986,671 in damages. Dorman was awarded $296,826 for her trial work. The verdict and trial fee awards were upheld on appeal. Dorman subsequently requested fees for her appellate work, and Supreme Court awarded Dorman $233,966. After a monetary dispute arose between Dorman and Appellants, Dorman sought a declaratory judgment to enforce the three retainer agreements. Supreme Court granted Dorman’s motion, and the Appellate Division affirmed, concluding that Dorman correctly interpreted the fee calculation. The Court of Appeals modified the Appellate Division order with regard to the trial agreement and otherwise affirmed, holding (1) the trial agreement entitled Dorman to one third of the jury award; and (2) because the trial agreement did not address the treatment of statutory counsel fees, Dorman was entitled to the more generous alternative of either one third of the jury verdict or the statutory award for her trial work. View "Albunio v. City of New York" on Justia Law

In 2010, the Department of Environmental Conservation (DEC) adopted amendments to regulations pertaining to the protection of endangered and threatened species. The amendments established a formal process through which individuals could obtain a permit to allow for the incidental taking of a threatened or endangered species. Before the agency implemented the regulations at issue, the Town of Riverhead and Twon of Riverhead Community Development Agency (collectively, Riverhead) challenged the amendments. Supreme Court dismissed the proceeding, finding that Petitioners did not have standing. The Appellate Division affirmed, concluding that Petitioners lacked standing based on their failure to allege an injury in fact and that Petitioners’ substantive challenges were not yet ripe. The Court of Appeals held that Petitioners could proceed with three of their procedural claims, as they alleged a sufficient injury regarding these claims, but Petitioners lacked standing with respect to the substantive causes of action, as those claims were not yet ripe. View "In re Ass'n for a Better Long Island" on Justia Law

In 2001, Defendant was found guilty of robbery and other crimes and sentenced to terms of imprisonment. Supreme Court later ordered that Defendant be resentenced, determining that Defendant’s sentence was illegal because it did not include a mandatory term of post-release supervision (PRS). After Defendant was conditionally released, Supreme Court resentenced Defendant by imposing a term of PRS. In 2009, the maximum term of Defendant’s prison sentence passed. In 2010, Defendant filed a motion to set aside his second sentence, arguing that the imposition of PRS constituted double jeopardy because he was out of prison on conditional release when it was imposed. Supreme Court granted the motion and resentenced Defendant, reimposing the terms of his completed initial sentence. The Appellate Division dismissed the People’s appeal, concluding that imposing PRS in this case would constitute double jeopardy. The Court of Appeals reversed, holding (1) Defendant had not acquired a legitimate expectation of finality in his sentence because the direct appeal of the sentence Defendant served was not over; and (2) therefore, the prohibition against double jeopardy was not implicated in this case. View "People v. Cintron" on Justia Law

In 1979, Plaintiff began his employment with Defendant, New York City Health and Hospitals Corporation (HHC), where he was eventually promoted to health facilities planner. In 2005, Plaintiff was diagnosed with pneumoconiosis, an occupational lung disease. In 2007, Defendant terminated Plaintiff. In 2008, Plaintiff filed a complaint alleging, among other claims, that HHC had unlawfully discriminated on the basis of disability in violation of the State Human Rights Law (State HRL) and the City Human Rights Law (City HRL). Supreme Court granted summary judgment for HHC, concluding that Plaintiff could not, even with a reasonable accommodation, perform the essential functions of his job. The Appellate Division affirmed. The Court of Appeals affirmed as modified, holding that HHC was not entitled to summary judgment with respect to Plaintiff’s State HRL and City HRL claims, as (1) both statutes generally preclude summary judgment in favor of an employer where the employer has failed to demonstrate that it responded to a disabled employee’s request for a particular accommodation by engaging in a good faith interactive process regarding the feasibility of that accommodation; and (2) under the facts of this case, Plaintiff presented colorable claims of disability discrimination under the City HRL and State HRL. View "Jacobsen v. New York City Health & Hosps. Corp." on Justia Law

After a jury trial, Defendant was found guilty of murder in the second degree for suffocating her stepdaughter. The Appellate Division found the jury verdict was against the weight of the evidence and modified the County Court’s judgment by reducing the murder conviction to a conviction of second-degree manslaughter. The Court of Appeals affirmed, holding (1) Defendant’s confession to the police following the child’s death was sufficiently corroborated by independent evidence at trial to support Defendant’s conviction; (2) the trial court did not abuse its discretion in admitting certain letters into evidence, as they were sufficiently redacted; and (3) Defendant was not denied effective assistance of trial counsel. View "People v. Santiago" on Justia Law