Justia Constitutional Law Opinion Summaries

Upon responding to a burglary report at an apartment building, police officers observed Defendant in the building’s stairwell. When the officers arrested Defendant for trespassing, one of the officers opened Defendant’s shoulder purse, which contained a loaded handgun. Defendant was subsequently indicted for criminal possession of a gun in the second degree and criminal trespass in the second degree. The trial court denied Defendant’s motion to suppress the gun, and, after a jury trial, Defendant was convicted of the counts charged. The Court of Appeals reversed, holding (1) the People bear the burden of demonstrating the presence of exigent circumstances in order to conduct a warrantless search of a closed container incident to arrest; and (2) in this case, the People failed to meet that burden as a matter of law. View "People v. Jimenez" on Justia Law

After a jury trial, Defendant was convicted of depraved indifference murder for murdering his infant son. The Appellate Division affirmed Defendant’s conviction. The Supreme Court reversed and directed a new trial, holding (1) the evidence was sufficient to demonstrate that Defendant, with depraved indifference to human life, recklessly engaged in conduct that created a grave risk of serious physical injury to the four-month-old, thereby causing the child’s death; but (2) Defendant’s previously denied motion to suppress inculpating statements he made to interrogators was in error because the statements were not demonstrably voluntary, and Defendant’s confession should not have been placed before the jury. View "People v. Thomas" on Justia Law

In 2010, Nassau County passed Local Law 18, which shifted the obligation to pay real property tax refunds from the County to its individual taxing districts. Various interested parties filed three actions seeking a declaration that Local Law 18 was null, void and unenforceable because its violated the Municipal Home Rule Law (MHRL) provisions limiting the powers of local government and the State Constitution’s home rule and taxation articles. Supreme Court effectively granted summary judgment to the County in all three actions. The Appellate Division reversed, entering a declaratory judgment that Local Law 18 violated the Constitution and the MHRL. The Court of Appeals affirmed, holding that the County exceeded its statutory and constitutional authority in its attempt to supersede a special State tax law. View "Baldwin Union Free Sch. Dist. v. County of Nassau" on Justia Law

After a nonjury trial, Defendant was convicted of unlawful surveillance in the second degree for standing outside the front door of his neighbor’s townhouse and filming the complainant while she was naked in her second floor bathroom. Defendant appealed, arguing that insufficient evidence supported his conviction. The Appellate Division affirmed, concluding that the evidence established that Defendant had surreptitiously recorded the complainant for his own amusement at a time and place where she had a reasonable expectation of privacy. The Court of Appeals affirmed, holding that each element of the offense of unlawful surveillance in the second degree was established beyond a reasonable doubt. View "People v. Schreier" on Justia Law

In 2000, Defendant pleaded guilty to first-degree manslaughter and was sentenced to twenty-three years incarceration. After Defendant’s incarceration, the Department of Correctional Services added a five-year PRS term to her certificate of commitment. In 2009, Defendant filed a pro se motion claiming that her plea was defective and her sentence illegal because she was not informed before she was incarcerated that she would be required to serve an additional term of PRS. Defendant was resentenced to the original sentence of twenty-three years without a term of PRS. Defendant appealed the resentence. Defendant’s counsel filed a motion under People v. Crawford asking to be relieved as counsel because there were no non-frivolous issues to be raised on Defendant’s behalf. Defendant subsequently filed a pro se supplemental brief arguing, inter alia, that the sentence was illegal. The appellate division granted counsel’s motion and affirmed the resentence without addressing Defendant’s pro se contentions. The Court of Appeals reversed, holding that the appellate division erred in granting the Crawford motion, and therefore, remittal for a de novo appeal was warranted. View "People v. Beaty" on Justia Law

In the first case involved in this appeal, Defendant pleaded guilty to criminal possession of marihuana. Defendant appealed, asserting that his plea was invalid because the record did not affirmatively demonstrate the waiver of his Boykin rights. The Appellate Term affirmed. In the second case, Defendant pleaded guilty to criminal sale of marihuana. Defendant appealed, arguing, as in the first case, that the waiver of his Boykin rights was nonexistent. The Appellate Term affirmed. The Court of Appeals reversed in both cases, holding that because the records in both cases were silent as to Defendant's waiver of his Boykin rights, the pleas must be vacated. View "People v. Tyrell" on Justia Law

In 2000, Defendant pleaded guilty to attempted assault in the first degree. The trial court orally sentenced Defendant to a fifteen-year determinate sentence of incarceration without pronouncing the term of postrelease supervision (PRS) required under N.Y. Penal Law 70.45. In 2008, the Legislature enacted N.Y. Penal Law 70.85, which makes an exception to section 70.45 by allowing a determinate sentence without a term of PRS to stand as a legal sentence. In 2010, the People moved to resentence Defendant under N.Y. Penal Law 70.85, and Supreme Court resentenced Defendant under section 70.85 to a determinate term of fifteen years without PRS. Defendant appealed, claiming that section 70.85 was unconstitutional because he denied him the right to vacate his guilty plea. The Court of Appeals affirmed, holding that section 70.85 is a constitutionally permissible legislative remedy for the defectiveness of a plea. View "People v. Pignataro" on Justia Law

After a jury trial, Defendants were convicted of first-degree robbery. Defendants appealed, arguing, among other things, that their counsel provided ineffective assistance by failing to assert as an affirmative defense that one of two weapons displayed during the gunpoint robbery was not "a loaded weapon from which a shot, readily capable of producing death or serious physical injury, could be discharged" pursuant to N.Y. Penal Law 160.15. The Appellate Division affirmed. The Court of Appeals affirmed, holding (1) defense counsel were not ineffective for neglecting to challenge the sufficiency of the evidence or for failing to put the affirmative defense before the jury; and (2) the record supported the lower courts' determination that the robbery victim's showup identification of Defendants was proper. View "People v. Howard" on Justia Law

Defendants in these three consolidated appeals were convicted of depraved indifference murder for driving in an outrageously reckless manner while intoxicated by alcohol or drugs and causing the death of at least one other person. Defendants challenged their convictions, contending that the evidence was not legally sufficient to support their convictions. Specifically, Defendants asserted that there was insufficient proof they had the requisite mental state of depraved indifference. The Court of Appeals affirmed the convictions, holding that there was sufficient evidence in each case that Defendants were aware of and appreciated the risks caused by their behavior. View "People v. Heidgen" on Justia Law

Plaintiffs here were a group of travel companies that enable customers to make online travel arrangements, including hotel reservations. Plaintiffs brought a declaratory judgment action challenging the constitutionality of Local Law 43, a hotel room occupancy tax applicable to online travel companies. Alternatively, Plaintiffs contended that the law did not apply to them because their service fees were not "rent" within the meaning of the state enabling legislation. Supreme Court held (1) the law was constitutional, and (2) the plain language of the state statute authorized the City's tax. The Appellate Division reversed, holding (1) the enabling legislation did not provide the City with broad taxation powers to tax Plaintiffs' fees, and (2) the City's tax was unconstitutional. The Court of Appeals reversed, holding that the City had the authority to enact the tax and that the Appellate Division erred when it declared the tax unconstitutional. View "Expedia, Inc. v. City of New York Dep't of Fin." on Justia Law