Justia Constitutional Law Opinion Summaries

Defendant was charged by felony complaint with numerous crimes relating to Defendant's procurement of loans to purchase properties using the personal identifying information of four mortgage loan applicants. Defendant waived his right to be prosecuted by indictment and pleaded guilty under a superior court information (SCI) to one count of grand larceny in the first degree and one count of scheme to defraud in the first degree. The appellate division vacated Defendant's plea, concluding that the SCI was jurisdictionally defective because it named victims not identified in the felony complaint. The Court of Appeals reversed, holding that the SCI served as a proper jurisdictional predicate for Defendant's guilty plea and was not defective. View "People v. Milton" on Justia Law

Defendants were convicted of conspiracy in the second degree and criminal possession of a controlled substance in the first degree for their respective roles in a drug-trafficking operation involving the movement of 400 pounds of cocaine from California to New York. The appellate division affirmed. Defendants appealed, arguing, among other things, that the trial court erred when it did not conduct an in-camera inquiry of a juror, who, prior to deliberations, wrote a note asking a question about the case. Defendants claimed that the use of the word "we" in the note implied that at least two of the jurors had been engaged in premature deliberations. The Court of Appeals affirmed, holding (1) absent some indication that the note-writing juror had engaged in some disqualifying conduct, the fact that one or more jurors may have engaged in premature deliberations or requested additional evidence was not sufficient to trigger a Buford inquiry; and (2) the remainder of Defendant's arguments were without merit. View "People v. Mejias" on Justia Law

After a jury trial, Defendant was convicted of one count of murder in the second degree. After retaining a new attorney for his appeal, Defendant moved to set aside the verdict, arguing that his trial counsel was ineffective. County Court denied the motion without a hearing. The Appellate Division affirmed the conviction, finding that, although trial counsel's representation may have been "unorthodox," it was not ineffective. The Court of Appeals reversed after noting that defense counsel's actions throughout this case showed an unfamiliarity with or disregard for basic criminal procedural and evidentiary law. The Court held that while defense counsel's errors in this case individually may not constitute ineffective assistance, the cumulative effect of counsel's actions deprived Defendant of meaningful representation. View "People v. Oathout" on Justia Law

Respondent was an inmate in the custody of the State Department of Corrections and Correctional Services (DOCCS). In 2010, Respondent undertook a month-long hunger strike, contending that he had ceased eating in order to secure transfer to another DOCCS facility and to bring attention to certain claims of mistreatment. After Respondent had lost 11.6 percent of his body weight, DOCCS commenced this proceeding requesting a court order permitting medical personnel to insert a nasogastric tube and take other reasonable steps necessary to provide hydration and nutrition to Respondent. Supreme Court granted DOCCS' motion. Respondent subsequently resumed eating solid food but nevertheless appealed. The Appellate Division concluded the case was moot except for the issue of whether the State violated Respondent's rights by securing the force-feeding order. On that issue, the Appellate Division ruled in favor of DOCCS, concluding that the force-feeding order did not violate Respondent's right to refuse medical treatment. The Court of Appeals affirmed, holding that Respondent's rights were not violated by the judicial order permitting the State to feed him by nasogastric tube after his health devolved to the point that his condition became life-threatening. View "Bezio v. Dorsey" on Justia Law

Defendant pleaded guilty to attempted first-degree robbery pursuant to a plea agreement. Defendant subsequently moved to withdraw his guilty plea, alleging, among other things, that the sentence promise was deficient because the judge did not explain to him at the time of the plea that a violation of post release supervision could result in his being incarcerated for up to five additional years of imprisonment, "over and above the ten years promised by the court." The county court denied the motion, and the appellate division affirmed. The Court of Appeals affirmed, holding the ramifications of a defendant's violations of the conditions of postrelease supervision are collateral consequences of a criminal conviction, are speculative at the time of the guilty plea, and are not a core component of the sentence imposed on the defendant by the judge. View "People v. Monk" on Justia Law

This appeal involved three defendants, who were charged with multiple counts of criminal sale of a controlled substance. In each case, the trial court concluded that the courtroom should be closed to the general public during the testimony of two undercover officers on the ground that closure was necessary to protect the officers' safety and ongoing investigations. After jury trials, Defendants were convicted as charged. At issue on appeal was whether the trial court properly closed the courtroom to the general public during the testimony of the undercover officers. The Court of Appeals held that the limited closures comported with Sixth Amendment public trial principles but that a new trial was required in one case based on an erroneous jury charge on the agency defense. View "People v. Echevarria" on Justia Law

After a jury trial, Defendant was convicted of attempted robbery, menacing, and possession of a weapon. Defendant appealed, arguing that the People violated N.Y. Crim. Proc. 710.30, which Defendant argued entitled him to the suppression of testimony about the victim's post-arrest identification. Defendant also argued that trial counsel's failure to raise that issue deprived him of the effective assistance of counsel. The Court of Appeals affirmed, holding that, assuming there was a section 710.30, if defense counsel did make a mistake in failing to object to the evidence, the mistake was not so egregious and prejudicial as to deprive Defendant of a fair trial. View "People v. Vasquez" on Justia Law

After his vehicle was stopped by a police officer, Defendant was arrested for driving while intoxicated, and a breathalyzer test computed his blood alcohol content at close to twice the legal limit. Defendant was subsequently indicted for felony DWI. During the jury trial, the People offered into evidence documents pertaining to the routine calibration and maintenance of the breathalyzer machine used in Defendant's breath test to demonstrate it was in proper working order at the time Defendant was tested. Defendant raised a Confrontation Clause challenge to the documents, contending that he was entitled to cross-examine the authors of the records. The county court allowed the documents to be received in evidence, and Defendant was convicted of felony DWI. The appellate division affirmed. The Court of Appeals affirmed, holding that documents pertaining to the routine inspection, maintenance, and calibration of breathalyzer machines are nontestimonial, and consequently, the Confrontation Clause was not implicated in this case, and the trial judge did not err in declining Defendant's request to cross-examine the authors of the testing records before the court ruled on their admissibility. View "People v. Pealer" on Justia Law

Defendant and three codefendants - Eric Young, Marvin Howard and Nathaniel Williams - were jointly indicted on a theory of accomplice liability for second-degree murder and second-degree weapon possession. Young and Howard waived their right to a jury, and Defendant and Williams were tried jointly. Howard testified during the trial. Defendant and Williams were convicted of both crimes, and the judge acquitted Howard. Defendant appealed on the ground that the judge's refusal to direct Howard to testify outside the jury's presence deprived him of his right to a fair trial. The appellate division agreed and reversed the judgment of conviction and sentence. The Supreme Court affirmed, holding that Defendant was prejudiced by the judge's decision to allow the jury to hear Howard's defense. View "People v. Warren" on Justia Law

Defendant was charged with criminal possession of a controlled substance in the first and third degrees and criminal possession of a weapon in the second degree. Defendant pleaded guilty to all three counts. At the time of the guilty plea, Defendant had a prior undischarged state sentence stemming from a felony drug conviction and also faced a federal violation of supervised release in connection with two prior federal felonies. Defendant was later sentenced to a determinate prison term of twelve years. The sentencing court stated that the sentence would be concurrent to the federal sentence. In addition, as a second felony drug offender, N.Y. Penal Law 70.25(2-a) required Defendant's twelve-year prison term to run consecutively to his prior undischarged state sentence. Defendant appealed, asserting that his guilty plea was involuntary because the trial court did not advise him of the consequence of his plea. The Court of Appeals affirmed, holding that the failure of the trial court to address the impact of section 70.25(2-a) during the plea colloquy did not require vacatur of the plea. View "People v. Belliard" on Justia Law