Justia Constitutional Law Opinion Summaries

The Court of Appeals reversed the order of the trial court applying New York's Rape Shield Law, N.Y. C.P.L. 60.42, to exclude forensic evidence proffered by Defendant to demonstrate that that the evidence the prosecution was seeking to attribute to him was consistent with masturbation or sexual contact with a third-party, holding that the trial court erred in applying the Rape Shield Law in this case, depriving Defendant of his constitutional right to present a defense.Defendant was charged with two counts of first-degree sexual abuse arising from allegations that he digitally penetrated his minor relative's vagina and fondled her breasts. The jury convicted Defendant of the sexual abuse charge related to the alleged digital penetration of the complainant's vagina. The appellate division affirmed. The Court of Appeals affirmed, rejecting Defendant's argument that the trial court improperly excluded the forensic evidence under CPL 60.42. The Court of Appeals reversed, holding that the trial court's exclusion of the forensic evidence at issue deprived Defendant of a meaningful opportunity to present a complete defense. View "People v. Cerda" on Justia Law

The Court of Appeals affirmed the order of the appellate division reversing Supreme Court's conclusion that the application of the Sexual Assault Reform Act (SARA) to Petitioner violated the Ex Post Facto Clause of the federal Constitution when applied to offenders whose crimes predated the 2005 amendments to the Act, holding that the effect of SARA's school grounds condition, as codified in N.Y. Exec. Law 259-c(14), was not punitive.In 1986, Petitioner was convicted of two counts of murder in the second degree and other crimes. Petitioner was unable to locate SARA-compliant housing before his open release date and therefore remained in custody until he could locate suitable housing under SARA's school grounds condition prohibiting him from living within 1,000 feet of a school. Petitioner filed a petition for a writ of habeas corpus arguing that SARA's residency restriction violated ex post facto principles. Supreme Court granted Petitioner's application and ordered his release. The appellate division reversed. The Court of Appeals affirmed, holding that the condition does not violate the Ex Post Facto Clause. View "People ex rel. Rivera v. Superintendent, Woodbourne Correctional Facility" on Justia Law

The Court of Appeals reversed the conclusion of the appellate division that the Sex Offender Registration Act (SORA) court acted within its discretion by upwardly departing to level three in determining Defendant's risk level classification, holding that the SORA court deprived Defendant of basic due process protections of notice and an opportunity to be heard.Defendant's convictions required him to register under SORA. At the SORA hearing, the court noted that Defendant would normally be required to register as a level two sex offender but upwardly departed to level three due to Defendant's "extensive prior disciplinary history." The appellate division affirmed. The Court of Appeals reversed, holding that the proceeding failed to comport with due process because Defendant was provided no notice or meaningful opportunity to be heard in response to the District Attorney's request for an upward departure. View "People v. Worley" on Justia Law

The Court of Appeals affirmed the judgment of the appellate division affirming the judgment of Supreme Court denying the County of St. Lawrence's action seeking a declaratory judgment that Local Law No. 2-2021 of the City of Ogdensburg was inconsistent with N.Y. Real. Prop. Tax Law (RPTL) 1150 or otherwise unconstitutional under the home rule article of the New York State Constitution, holding that there was no error.The law at issue in this case repealed a prior local law validly opting out of the application of RPTL article 11. The County commenced this proceeding arguing that the law was not in accord with state law and impaired the rights of the County and the County Treasurer. Supreme Court denied the petition and declared the law to be valid and enforceable. The appellate division affirmed. The Court of Appeals affirmed, holding that the law did not violate the statutory and constitutional protections at issue in this case but effectuated a power granted by the legislature to cities wishing to revoke their opt-out from article 11. View "St. Lawrence County v. City of Ogdensburg" on Justia Law

The Court of Appeals reversed the order of the appellate division affirming Defendant's conviction, following a jury trial, of second-degree murder and second-degree weapon possession, holding that Defendant's Sixth Amendment right to a public trial was violated in this case and that Defendant was entitled to a new trial.For the last four days of Defendant's eight-day jury trial, which included the testimony of several witnesses, summations, and the jury's verdict, the trial court ordered the courtroom closed to the public and all interested spectators. At the conclusion of trial the jury found Defendant guilty. The appellate division affirmed. The Court of Appeals reversed and remanded the case for a new trial, holding that the record did not demonstrate that "unusual circumstances" necessitated closure of the courtroom, and therefore, the trial court improperly abridged Defendant's constitutional right to a public trial. View "People v. Reid" on Justia Law

The Court of Appeals reversed the denial of Defendant's motion to suppress evidence seized as a result of a stop and frisk, holding that the circumstances of this case did not warrant a level three stop and frisk under People v. De Bour, 40 N.Y.2d 210 (1976).Defendant, who was stopped and frisked after he existed a parked car and walked down the street, filed a motion to suppress drugs found on his person as the fruits of an illegal search and seizure. The trial court denied the motion to suppress, and Defendant was subsequently convicted of two counts of criminal possession of a controlled substance in the third degree. The appellate division affirmed. The Supreme Court reversed and directed that the indictment be dismissed, holding that the police officer lacked reasonable suspicion to justify the stop and frisk of Defendant. The Court of Appeals reversed, holding that the minimum standard required to justify a stop and frisk under People v. De Bour, 40 N.Y.2d 210 (1976), was not met in this case. View "People v. Johnson" on Justia Law

The Court of Appeals reversed the decision of the appellate division affirming the judgment of the trial court convicting Defendant of rape in the first degree, holding that Defendant's constitutional right to prompt prosecution under the due process clause of the New York Constitution was violated in this case.The complainant reported to the police that she had been raped a few hours earlier by Defendant, whom she identified. The complainant submitted to a sexual assault examination, but Defendant, who was questioned by the police the same day, but refused to provide a DNA sample. Years later, a sample of Defendant's DNA sample was obtained via a buccal swab, which disproved Defendant's claim that he and the complainant had not had sex. More than four years after the complainant reported the assault, the People filed an indictment against Defendant. Defendant moved to dismiss the indictment on the grounds that the excessive preindictment delay violated his due process right to prompt prosecution. County Court denied the motion, and Defendant was convicted. The appellate division affirmed. The Court of Appeals reversed and dismissed the indictment, holding that the delay of the police and prosecutors violated Defendant's constitutional right to a prompt prosecution. View "People v. Regan" on Justia Law

The Court of Appeals reversed Defendant's conviction of one count each of attempted assault in the first degree and assault in the second degree and two counts of criminal contempt, holding that the trial judge committed constitutional error by ordering Defendant handcuffed without placing the special need for such restraints on the record and that the error was not harmless.The trial judge ordered Defendant to be handcuffed when the jury returned to announce its verdict. The judge, however, did not provide an on-the-record, individualized explanation for the restraints. The appellate division affirmed, concluding that any error in Defendant's being handcuffed without any explanation on the record was harmless. The Court of Appeals reversed, holding (1) until the jury returns to the courtroom, publicly announces the verdict and confirms the verdict, the defendant is still presumed innocent and the constitutional prohibition on restraining a defendant without explanation remains in force; and (2) the constitutional error in this case was not harmless beyond a reasonable doubt, requiring a new trial. View "People v. Sanders" on Justia Law

The Court of Appeals affirmed the judgment of the appellate division reversing Supreme Court's order granting the petition filed by the City of Yorkers pursuant to N.Y. C.P.L.R. 75 to permanently stay arbitration of the underlying labor dispute, holding that grievances like the present one are arbitrable so long as no public policy, statutory, or constitutional provisions prohibit them and they are reasonably related to the provisions of the collective bargaining agreement (CBA).The underlying dispute between City of Yonkers and its firefighters concerned whether Yonkers must make certain types of payments to firefighters who were permanently disabled for work-related injuries and who qualified for benefits under N.Y. Gen. Mun. Law 207-a(2). Yonkers Fire Fighters, Local 628, IAFF, AFL-CIO (the Union) filed a grievance alleging that Yonkers violated the CBA and then served a demand for arbitration. Yonkers responded by filing a petition to permanently stay arbitration. Supreme Court granted the petition. The appellate division reversed. The Court of Appeals affirmed, holding that this grievance was arbitrable. View "City of Yonkers v. Yonkers Fire Fighters, Local 628, IAFF, AFL-CIO" on Justia Law

The Supreme Court reversed the decision of the appellate term holding that the evidence was legally insufficient to support Defendant's conviction of harassment in the second degree beyond a reasonable doubt, holding that the evidence was sufficient to support the conviction.At issue on appeal was whether Defendant's statements to the victim that her children "were going to get a bullet in their heads" and that he was going to firebomb her home and kill her and her family were serious and unequivocal threats of physical harm. The appellate term concluded that Defendant's speech did not constitute a violation of the second-degree harassment statute. The Supreme Court reversed, holding that the evidence was sufficient for a reasonable trier of fact to conclude that Defendant threatened the victim with physical contact of a serious nature, with the intent to harass, annoy or alarm her. View "People v. Lagano" on Justia Law