Justia Constitutional Law Opinion Summaries

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

After a jury trial, Appellant was convicted of sexual abuse in the first degree and endangering the welfare of a child. Prior to Appellant's release from prison, the Department of Correctional Services transferred Appellant to Kirby Psychiatric Center. During his confinement at Kirby, the State filed a N.Y. Mental Hyg. Law 10 civil management petition against Appellant. A jury found that Appellant suffered from a mental abnormality, and the court assigned him to the Office of Mental Health for confinement in a secure facility. Appellant appealed, arguing, inter alia, that Supreme Court erred when it allowed experts to testify to unreliable hearsay when the hearsay served as the underlying basis for the experts' opinion. The Appellate Division affirmed. The Court of Appeals reversed and ordered a new trial, holding (1) the trial court improperly permitted the State's experts to introduce certain unreliable hearsay as well as some hearsay with a patina of reliability that nevertheless was more prejudicial than probative as a matter of law; and (2) these errors denied Appellant due process. View "State v. Floyd Y." on Justia Law

At issue in these consolidated criminal appeals was whether, prior to permitting a defendant to plead guilty to a felony, a trial court must inform the defendant, if the defendant is not U.S. citizen, that he or she may be deported as a result of the plea. The Court of Appeals held that due process compels a trial court to apprise a defendant that, if the defendant is not a U.S. citizen, he or she may be deported as a consequence of a guilty plea to a felony. In so holding, the Court (1) overruled the portion of its decision in People v. Ford which held that a court's failure to advise a defendant of potential deportation does not affect the validity of the defendant's plea; and (2) held that the trial court's failure to notify a pleading non-citizen defendant of the possibility of deportation does not entitle the defendant to automatic withdrawal or vacatur of the plea, but rather, in order to overturn his or her conviction, the defendant must establish the existence of a reasonable probability that, had the court warned the defendant of potential deportation, the defendant would have rejected the plea and opted to go to trial. View "People v. Peque" on Justia Law

Defendant was charged with one count of criminal possession of a weapon in the second degree for possessing a loaded firearm. The count was based on evidence that a loaded gun was found in Defendant's home. With the indictment, the People filed a special information alleging that Defendant had previously been convicted of criminal possession of a controlled substance in the first degree. Supreme Court reduced the charge to third degree possession. The Appellate Division reversed and reinstated the second degree charge. At issue on appeal was whether Defendant was entitled to rely on the so-called "home or business" exception in the definition of second degree weapon possession despite his prior conviction. The Court of Appeals affirmed, holding that because Defendant had a previous conviction, the exception did not apply. View "People v. Jones" on Justia Law

Defendant, a convicted criminal, was convicted of the class C felony of criminal possession of a weapon in the second degree and sentenced to three and one-half years in prison for possessing a loaded weapon in his home. Defendant appealed, arguing that, while the State did have power to punish him for having an unlicensed handgun in his home, his conviction infringed on his Second Amendment right to keep and bear arms where his punishment was unusually severe. The Appellate Division affirmed the conviction and sentence. The Court of Appeals affirmed, holding that Defendant's sentence did not raise constitutional problems in this case. View "People v. Hughes" on Justia Law