State Supreme Court Data Tracker

Summary of Case Context & HoldingPlaintiff, a construction worker, slipped on ice and fell to the floor while wearing stilts to install ceiling insulation. At issue was whether plaintiff's accident fell within the scope of Labor Law § 240(1). Under Labor Law § 240(1), owners and contractors engaged “in the erection, demolition, repairing, altering, painting, cleaning or pointing of a building or structure,” except certain owners of one- and two-family dwellings, must “furnish or erect ... scaffolding, hoists, stays, ladders, slings, hangers, blocks, pulleys, braces, irons, ropes, and other devices which shall be so constructed, placed and operated as to give proper protection to a person” employed in the performance of such labor. The Court of Appeals held that, under Melber v. 6333 Main St., 91 N.Y.2d 759 (1998), plaintiff's accident did not fall within the scope of Labor Law § 240(1) because the ice upon which he slipped was an ordinary slipping hazard unrelated to an elevation risk.

Summary of Case Context & HoldingPlaintiff NL Industries, Inc., a lead-smelting company, filed claim against the state seeking contribution under the New Jersey Spill Compensation and Control Act (Spill Act) for environmental-contamination cleanup costs for a coastal site on which company's slag was used on an existing jetty still owned by the state and was used to build a seawall on a riparian land grant from the state before the Spill Act went into effect. The fundamental issue is whether the Spill Act retroactively abrogated the state's sovereign immunity for state action taken prior to the Act's 1977 effective date. If determined that the state can be liable for its activities during the pre-Spill Act time period, then the Supreme Court must decide two other questions that were presented in the appeal: whether the state can be liable under the Spill Act for actions taken as a regulator; and whether state liability under the Spill Act must be harmonized with the New Jersey Tort Claims Act, N.J.S.A. 59:1–1 to 12.3, which, among other things, provides the state with immunity from tort claims for certain categories of discretionary activities. The Supreme Court held that as a matter of first impression, the state sovereign immunity prevails against Spill Act contribution claims based on state activities that occurred prior to the original effective date of the Spill Act. The Supreme Court reasoned that it failed to see any statutory support or legislative intent whatsoever to abrogate the sovereign immunity otherwise applicable to the state's activities occurring before the Spill Act became effective in 1977.

Summary of Case Context & HoldingNYC CLASH, a not for profit corporation dedicated to advancing and promoting interests of smokers, appealed a regulation that prohibited smoking in certain areas within parks, historical sites, and recreational facilities operated by the Office of Parks, Recreation, and Historic Preservation (OPRHP). NYC CLASH challenged the regulation as unconstitutional and in violation of the separation of powers doctrine. When determining whether agency rulemaking has exceeded legislative fiat, the circumstances to be considered are whether (1) the agency did more than balance the costs and benefits according to preexisting guidelines, but instead made value judgments entailing difficult and complex choices between broad policy goals to resolve social problems; (2) the agency merely filled in details of a broad policy or if it wrote on a clean slate, creating its own comprehensive set of rules without benefit of legislative guidance; (3) the legislature has unsuccessfully tried to reach an agreement on the issue, which would indicate that the matter is a policy consideration for the elected body to resolve; and (4) the agency used special expertise or competence in the field to develop the challenged regulation. Boreali v. Axelrod, 517 N.E.2d 1350 (1987). The Court of Appeals weighed those factors and held that the legislature delegated to OPRHP "the authority to provide for the health, safety, and welfare of the public in connection with its oversight of the state park system" and the agency acted within the confines of that delegated power in promulgating the regulation at issue.

Summary of Case Context & HoldingWhen a worker suffers a job-related disability that is permanent but partial, and the worker’s wage income is reduced, the worker may be eligible for benefits under the Workers’ Compensation Law if the worker demonstrates a causal link between the disability and the reduction in income. When claimant filed for such relief, her former employer conceded that claimant was permanently partially disabled and that she had involuntarily retired from her former employment, but argued that her lack of income was caused not by her disability but by her unwillingness to find other work. Under Matter of Zamora v. New York Neurologic Assoc., 19 N.Y.3d 186 (2012), the Workers’ Compensation Board can infer from a permanent partial disability claimant’s involuntary retirement from a former job that the claimant’s disability caused the claimant’s reduction in earnings; whether the Board should do so depends upon the nature of the disability and the nature of the claimant’s work in a given case. After awarding claimant worker’s compensation relief and successfully defending that award before the Appellate Division, the Board reversed course before the Court of Appeals, saying its internal practice was to infer causation from involuntary retirement only when the employer did not contest causation, and to always require that claimant demonstrate willingness to work if the employer did contest causation; it had wrongly deviated from that practice here.

Summary of Case Context & HoldingPlaintiff, a worker at the One World Trade Center construction site, sustained injuries when he slipped and fell while descending an exterior metal staircase (also referred to as a temporary scaffold) that was wet from exposure to the elements. The issue on appeal was whether the Appellate Division properly determined that plaintiff was entitled to summary judgment on liability on his Labor Law § 240(1) cause of action. Under Labor Law § 240(1), owners and contractors engaged “in the erection, demolition, repairing, altering, painting, cleaning or pointing of a building or structure,” except certain owners of one- and two-family dwellings, must “furnish or erect ... scaffolding, hoists, stays, ladders, slings, hangers, blocks, pulleys, braces, irons, ropes, and other devices which shall be so constructed, placed and operated as to give proper protection to a person” employed in the performance of such labor. Finding that there were triable issues of fact as to whether the staircase provided sufficient protection, the Court of Appeals held that summary judgment should not have been granted in plaintiff’s favor on the issue of liability. In particular, there were conflicting expert opinions as to the adequacy of the staircase as a safety device. The Court of Appeals also reiterated that the mere fact that plaintiff fell did not, in itself, establish a violation of Labor Law § 240(1).

Summary of Case Context & HoldingIn 1996, defendant was convicted with a series of crimes. At sentencing, defendant refused to apologize to the deceased victim's family and laughed, so the Court of Appeals ultimately imposed an aggregate term of more than 66 years to life in prison. On appeal in 2000, the appellate counsel specifically argued that, at the time of defendant's arrest, the police conducted an illegal search, but the Appellate Division affirmed the judgement of conviction. In 2017, defendant commenced this proceeding claiming that the appellate counsel's performance was constitutionally defective because he allegedly failed to communicate with defendant during the pendency of his direct appeal, submitted an appellate brief that was poorly structured and that did not challenge the length of the minimum portion of the indeterminate sentence imposed as unduly harsh and severe in the interest of justice, and neglected to file a criminal leave application seeking leave to appeal to this Court. The Appellate Division denied defendant's application. The Court of Appeals decided that the intermediate appellate court correctly determined that the quality of counsel's appellate brief did not constitute ineffective assistance because, while the brief could have been better drafted, the brief demonstrated appellate counsel's grasp of the relevant facts and law, and the intermediate appellate court addressed each of the four reviewable issues raised by appellate counsel; thus, the intermediate appellate court properly denied defendant's petition for a writ of error coram nobis.

Summary of Case Context & HoldingDefendant, who only spoke Spanish, was arrested and charged with a Driving While Intoxicated but was not given a Physical Coordination Test (three tests consisting of: walk and turn, the one-leg stand and finger to nose) during the arrest, as is NYPD policy for non-English speakers. Defendant argued this policy violated his equal protection and due process rights under both State and Federal Constitutions. For the Equal Protection claim, the Court of Appeals held that the NYPD policy survives rational basis review as the public has an interest in ensuring the results from these lengthy and ubiquitous tests are neither unreliable nor administratively overburdensome (as would be the case if tests required translators). For the Due Process claim, the Court of Appeals held that defendants do not have a constitutional due process right to Physical Coordination Tests or other discretionary investigative techniques.

Summary of Case Context & HoldingIn 1996, defendant was convicted on several drug charges and accepted a plea deal which rendered him subject to deportation, a consequence of which he was unaware. Defendant later moved to vacate his conviction, arguing that, per the U.S. Supreme Court's 2010 ruling Padilla v Kentucky, 559 U.S. 356 (2010), his counsel's failure to advise him on the immigration consequences of his plea deal made his counsel ineffective. The Court of Appeals held that while Padilla does require the court to include advice about the immigration consequences of a guilty plea, it barred this requirement from being applied to cases made before the Padilla ruling.

Summary of Case Context & HoldingDefendant, an African-American man, was charged for robbery after being identified by two white victims as the man who had robbed them, in the absence of any physical evidence. The trial court denied the defendant’s request to instruct the jury that there is a near scientific tenet that people have more difficulty identifying members of different races than they do identifying members of their own race. The Court of Appeals held that when identification is an issue in a criminal case and witnesses and the defendant are of different races, defendants are entitled to instruct the jury on this cross-race effect.

Summary of Case Context & HoldingIn trial court, defendant was convicted upon a jury verdict of murder in the second degree, multiple counts of criminal contempt, and offering a false instrument for filing. He was sentenced to a term of imprisonment of 23 years to life. Nine years after he was sentenced, defendant moved pro se to vacate his convictions under CPL § 440.10, arguing that he was improperly forced to wear a stun belt throughout his trial. It is undisputed that sheriff officials required defendant to wear a stun belt at trial, that neither the State nor the trial court were aware of that fact, and that defendant failed to preserve any argument concerning the stun belt. Because the trial court did not articulate a particularized need for defendant to wear a stun belt, the use of that restraint was error. However, this flaw was not a mode of proceedings error (see People v Buchanan, 884 N.Y.S.2d 337, 912 N.E.2d 553 (2009)). The courts thus did not abuse their discretion by summarily denying the portion of defendant's CPL §440.10 motion based on his unpreserved assertion of a Buchanan error, which could have been raised before the trial court.

Summary of Case Context & Holding"Batson challenges" are challenges to a prosecutor's decisions to exclude a member of the jury pool by analyzing whether these exclusions are discriminatory (e.g., striking only one race or gender from the jury pool). In this case, defendant was a dark-colored Black male charged with robbery. During jury selection, defendant's counsel lodged a Batson challenge after the prosecutor excluded five dark-skinned women (four Black women and one Indian-American woman), a challenge which was rejected on the grounds that skin color was not a cognizable class for which a challenge can be lodged. Siding with the defendant, the Court of Appeals held that skin color, is, indeed, a cognizable class under the State constitution, for which a Batson challenge can be lodged.

Summary of Case Context & HoldingCo-defendants were convicted of murder, based largely on the eyewitness testimony of the landlord of the apartment where the victim was killed. This eyewitness, a habitual user of crack cocaine and methadone, failed to appear twice in court, and was twice privately questioned by the trial judge about this failure in conversations that were not transcribed, and in the absence of co-defendants' counsel, despite their request to be present after the first private discussion. Ordering a new trial, the Court of Appeals held that these conversations, as well as examinations of witnesses privately by a judge or with only one side's counsel present, generally violate the defendants' Sixth Amendment rights to counsel and to confrontation when these examinations pertain to substantive issues -- in this case, the eyewitness's credibility.

Summary of Case Context & HoldingDefendant was arrested on a robbery charge brought to a station with video recording devices to be interrogated, despite there being a station equipped with such devices nearby. There, the police said the defendant made statements that incriminated him. At trial, defendant's counsel requested an "adverse interference instruction" to tell the jury they should question the voluntariness and basic existence of these statements given the absence of an electronic recording, and argued that such instructions should be mandatory whenever the police fail to record an interrogation. The Court of Appeals disagreed, holding that the police have no universal duty to record video interrogations.

Summary of Case Context & HoldingDefendant, a high-ranking police officer, was charged with conspiracy and official misconduct for intervening in a larceny case in which the suspect was the son of a police benefactor. Defendant argued that the grand jury should not have heard hearsay statements made by the co-conspirators at times in which the defendant was not involved, and that the prosecution had not met its evidentiary burden. Looking at the totality of circumstances, the Court of Appeals found that the prosecution had given sufficient evidence, and that hearsay statements from co-conspirators before and after a defendant's involvement in said conspiracy may be admitted into evidence.

Summary of Case Context & HoldingDefendant was convicted of second degree murder, evidence for which included a confession he maintained was false and coerced by police after physical and psychological abuse. One of his interrogators had previously worked on a case allegedly involving a false confession, a fact that the court had suppressed. Defendant then moved to vacate his conviction, arguing that suppressing this fact was a Brady violation -- i.e., a violation of a defendants right to receive all evidence the prosecution that could prove his case or hinder the prosecution's. The Court of Appeals maintained the conviction, ruling that no Brady violation had occurred, because the government was not aware of the interrogator's past misconduct at the time of the trial, and had no duty to discover and disclose such information.

Summary of Case Context & HoldingAfter hearing knocks on his door, defendant opened the door of his home to police officers, who then arrested him in the doorway, without a warrant, in relation to several charges of robbery of which he was later convicted. In a motion to suppress, defendant argued the police had unconstitutionally entered his home without consent or a warrant. The Court of Appeals sided with the police, ruling that warrantless "threshold/doorway arrests" are constitutional, and that police may knock on a door in order to lure a subject to the threshold of a home for this purpose, so long as they do not compel or threaten the subject.

Summary of Case Context & HoldingIn Matter of Abe A., 56 NY2d 288 (1982), this Court set forth a three-prong standard for seizure of corporeal evidence from an uncharged suspect that requires bodily intrusion: the State must demonstrate probable cause to commitment of the crime, a "clear indication" that material and relevant evidence will be found, and that the means used for the seizure is "safe and reliable." Generally, when the corporeal evidence sought is not subject to alteration or destruction, there is no exigency and the search warrant application must be brought on notice to the suspect. In this case, the police sought a search warrant authorizing them to obtain corporeal evidence — in the form of DNA evidence by use of a buccal swab — from defendant, a suspect in a murder investigation who was in custody on an unrelated matter. The Court of Appeals held that there was no violation of defendant’s constitutional rights where he was given notice and an opportunity to be heard prior to the issuance of the warrant on the nature and extent of the bodily intrusion. The Court of Appeals further develops the rule by deciding that Abe and the constitutional right to be free from unreasonable searches and seizures do not require that a defendant be given access to search warrant materials and an adversarial hearing as a matter of constitutional law, as the probable cause determination is one that is made by the neutral magistrate as a matter of course because a buccal swab was undeniably safe, consisted of a minimal intrusion and involved no discomfort, and the method and procedures employed in taking the saliva undoubtedly respected relevant Fourth Amendment standards of reasonableness.

Summary of Case Context & HoldingDefendant swore at officers and claimed they were harassing him in a subway station in Manhattan, after which the officers followed the defendant to another level of the station, prevented him from leaving, searched him and found an illegal knife. The defendant moved to suppress the knife on the grounds the police stop was illegal. The Court of Appeals agreed and dismissed the indictment, holding that shouting obscenities at officers does not constitute disorderly conduct.

Summary of Case Context & HoldingDefendant, at trial for attempted armed robbery, was represented by a lawyer from the Legal Aid Society. This lawyer informed the trial court that he was leaving the Legal Aid, after which the trial court rejected a request for adjournment so that a new Legal Aid attorney could have time to prepare themselves for trial. The trial court also relieved the Legal Aid Society over its objections and appointed the defendant new counsel, at a hearing in which defendant was present but not consulted. Defendant plead guilty, then sought to withdraw his plea and have new counsel assigned. The Court of Appeals held that relieving Legal Aid as defendant's counsel without consulting the defendant deprived him of his Sixth Amendment right to counsel, and that such a claim was not barred by defendant's guilty plea.

Summary of Case Context & HoldingDefendant was convicted of second degree murder, in part based on a 49.5 hour interrogation during which he did not sleep and only received one meal. On appeal, defendant argued that statements made during interrogation, as well as subsequent inculpatory statements 10 hours later, should be suppressed as evidence. The Court of Appeals ruled that statements made in both of these interrogations should have been suppressed and that both were tainted by the police misconduct in the initial interrogation

Summary of Case Context & HoldingDefendant was stopped by an officer after driving past an unregistered and therefore legally unauthorized stop sign. After this stop, the defendant was arrested and charged with both failing to stop at a stop sign and driving while intoxicated. The defendant argued that the lack of legal authorization for the stop sign created a lack of probable cause for the officer's stop, so no evidence from the stop should be admitted. The Court of Appeals disagreed, ruling that when an officer has an "objectively reasonable" belief that they have probable cause for a stop, the evidence from the stop is admissible as evidence, even if the officer is mistaken that they have such probable cause due to either a mistake in fact or law.

Summary of Case Context & HoldingDefendant was charged with three assaults on three separate deputy sheriffs based on a fight at a correctional facility. The defendant claimed a deputy initiated this fight. The deputies denied this and alleged to have watched a video recorded by the facility that proved their case, a video that was destroyed before trial. At trial, a request for an "adverse inference charge" to the jury, instructing them to question the validity of the testimony by the deputy about the existence and contents of the video, was denied. The Court of Appeals held that such a charge should be given where a defendant has requested evidence likely to be important to the case, and where this evidence has been destroyed by the State.

Summary of Case Context & Holding"[W]hen a defendant has been convicted of an armed felony and the only barrier to his or her youthful offender eligibility is that conviction, the court is required to determine on the record whether the defendant is an eligible youth by considering the presence or absence of the factors set forth in CPL §720.10 (3)" (People v Middlebrooks, 25 NY3d 516, 527-528 [2015]; accord People v Lofton, 29 NY3d 1097, 1098 [2017]). Here, the State conceded that the sentencing court failed to make any appropriate on-the-record determination. The Court of Appeals accepted the State's concession and, accordingly, the case should be remitted for consideration of youthful offender treatment.

Summary of Case Context & HoldingWhile being processed for an arrest at the Franklin County Jail, defendant was directed to remove his footwear, a command given to all those in custody at jail, but defendant refused to do so despite multiple orders regarding this. A police sergeant called for backup and specifically warned defendant that he would pepper spray defendant if he refused to remove his footwear. Defendant continued to refuse, was pepper sprayed in the face, and punched the sergeant in the head. Defendant was charged with assault in the second degree. The Appellate Division concluded that there was a reasonable view of the evidence that the use of the pepper spray constituted excessive force. The Court of Appeals, viewing the evidence in the light most favorable to defendant, decided that defendant's contention that the force exerted was unlawful is without merit, and no reasonable factfinder could conclude on this record that defendant reasonably believed that the use of force was necessary to defend himself from the use of unlawful physical force. Order reversed and case remitted to the Appellate Division.

Summary of Case Context & HoldingPolice officers, having observed defendant exit and reenter a building in a public housing development several times, possessed the requisite objective credible reason to approach him and ask briefly about his identity, destination, or reason for being in the area. However, after defendant explained that he was visiting a friend who lived in the building, and provided his identification, the encounter rose beyond a level-one request for information, which, according to the Court of Appeals, the State failed to justify as lawful. An officer took defendant's identification to the eleventh floor of the building to verify whether the occupant of the apartment defendant identified knew him, while another officer instructed defendant to "stand right there" under the watch of two officers, and when the first officer returned, having determined that the occupant of the apartment did not know defendant, defendant was arrested for trespassing. The State justified the officers' interaction with defendant purely on the ground that it was a level-one inquiry supported by an objective credible reason. The Court of Appeals found that the record demonstrated that the encounter thereafter rose beyond a level-one request for information, which the State failed to justify as lawful. Accordingly, defendant's motion to suppress drugs recovered from his person during a search incident to his arrest was granted.

Summary of Case Context & HoldingThe Court of Appeals considered whether, defendant, a youthful offender, was entitled to a jury instruction on voluntary possession of a weapon. Defendant testified that, while sitting in an apartment where he had rented a room for the evening, he was shot by someone outside of the apartment. He further testified that, after running into the bedroom he had rented to search for a towel to stop the bleeding from his gunshot wound, he saw what appeared to be a gun in an open drawer. Police arrived shortly thereafter and transported defendant to the hospital. Police also searched the apartment and found a number of weapons and marihuana. Defendant was charged with criminal possession of a weapon and unlawful possession of marihuana. With respect to the gun found in the drawer, defendant argued that the jury should be instructed that possession had to be voluntary, meaning that he “was aware of his . . . physical possession or control . . . for a sufficient period to have been able to terminate the possession” (CJI2d [NY] Possession — Voluntary Possession § 15.00 [2]). The Court of Appeals held that, when the evidence was viewed in the light most favorable to defendant, there was a reasonable view that he had constructively possessed the weapon but that his awareness was so fleeting that any possession was not voluntary. The Court of Appeals thus concluded that the evidence supported the requested jury charge and the error warranted a new trial on the voluntary possession count.

Summary of Case Context & HoldingDefendant was questioned for 28 hours across three days about the death of a former partner and her brother, during which he confessed to their murders, along with related crimes. The Defendant moved to suppress his statements to the police, saying they were coerced and that he did not knowingly and intelligently waive his Miranda rights due to his limited English proficiency. The Court of Appeals held that, while the delays by the police were unnecessary, the totality of circumstances--e.g., the defendant was supplied with food, water, and cigarettes, the interrogation was not continuous and allowed defendant breaks to sleep and consider his situation, and conversed multiple times with officers in English--showed that defendant's statements were voluntary.

Summary of Case Context & HoldingThe circumstances (as described below) did not warrant a level three De Bour stop and frisk (which requires reasonable suspicion determination by the officer), and the evidence seized as a result of the frisk had to be suppressed where the officer's observations of defendant moving from the driver's seat to the passenger seat of his parked car, moving his upper torso back toward the driver's seat, pulling up his pants and attempting to buckle his belt, and appearing nervous while being questioned did not support a reasonable view that defendant was armed, had committed a crime, or was about to commit a crime. Thus, the officer lacked reasonable suspicion to justify the stop and frisk after defendant exited a parked car and walked down the street.

Summary of Case Context & HoldingDefendant, while held in Rikers Island on robbery charges, made several incriminating statements during phone calls to friends and family, which, per Department of Correction's policy, were recorded and handed over to the prosecution. At trial, the defendant argued that the Department's practice of recording and disseminating to District Attorneys' offices all non-privileged and non-exempted phone calls from inmates violated inmates' right to counsel. The Court of Appeals sides with the prosecution, holding that no agent of the government deliberately elicited incriminating statements from inmates on these phone calls and notes that defendant had several notices that his calls were being recorded, while also stating this ruling should not be viewed as the Court of Appeals approving of this policy.

Summary of Case Context & HoldingDefendant was driving when she swerved into an adjacent lane and struck another vehicle. Two people in the other vehicle were killed and defendant was taken to the hospital. At the time, defendant was 34 weeks' pregnant and the hospital found signs of fetal distress so she agreed to an emergency cesarean section. The baby died six days later. The autopsy confirmed the cause of death was due to injuries sustained during the accident. The defendant was indicted on three counts of manslaughter, one count of aggravated vehicular homicide, and one count of operating a vehicle while under the influence. Defendant was traveling in excess of 50 mph in a 30 mph zone, while under the influence of a prescription drugs and alcohol, and was not wearing a seat belt. Defendant was only convicted on manslaughter in the second degree for the death of her child. The Court of Appeals reversed holding the legislature did not intend to hold pregnant women criminally responsible for engaging in reckless conduct against themselves and their unborn fetuses, such that they should be subject to criminal liability for prenatal conduct resulting in postnatal death.

Summary of Case Context & HoldingTwo defendants pled and were found guilty, respectively, for armed robberies committed when they were 18 years old. Many crimes committed by 16- to 19- year old are categorically eligible for determination of Youth Offender status, which comes with more favorable sentencing, based on the case People v. Rudolph, 974 N.Y.S.2d 885, 997 N.E.2d 457 (2013). Defendants argued that their status as "eligible youth" requires that they should have received a Youth Offender determination, however, armed robberies are only eligible for this more favorable sentencing in the presence of mitigating factors. The Court of Appeals found that such mitigating factors were not present, and as a result, neither defendant received Youth Offender determinations.

Summary of Case Context & HoldingDefendant, at age 18, plead guilty to several assault and attempted murder charges and was denied Youth Offender status based in part from a confidential document that was not shared with nor disclosed to the defendant. Defendant argued that he was entitled to an explanation of the reasoning for denying him this status as well as to disclosure of the confidential document. In looking at CPL § 720.20, the Court of Appeals held that a defendant is not entitled to the reasoning behind the denial of Youth Offender status. However, in this particular case, defendant's due process rights were violated by the sentencing court refusing to disclose the confidential document.

Summary of Case Context & HoldingDefendant moved to dismiss charges of driving while his ability were impaired in front of a judge in City Court, who denied the motion. This same judge then proceeded over both the bench trial in which the defendant was ultimately convicted, and the County Court trial in which the defendant appealed this conviction. The Court of Appeals decided that a judge who presided at a trial may not act as the appellate judge in the same case, as they would likely not be or appear to be an impartial jurist. This ban does not apply to judges who proceed over different stages of a trial, since at this stage there is still the availability of further appellate review.

Summary of Case Context & HoldingDefendant, charged with murder based on confessions during an interrogation, was assessed by psychiatric experts to have issues of concentration, memory, intelligence and auditory hallucinations. His counsel at trial decided not to execute subpoenas for or otherwise review these assessments as evidence of defendant's mental weakness, which could have rebutted the voluntariness of his admissions, due both to poor strategy and a misunderstanding of criminal discovery law. After sentencing, defendant obtained new counsel which moved to vacate the conviction, arguing trial counsel's failures represented ineffective representation. The Court of Appeals held that defendants' right to representation was violated by his counsel's failure to secure and review crucial documents to defendant's case. A strategy involving "a total failure to investigate the facts of a case, or review pertinent records," does not constitute meaningful representation.

Summary of Case Context & HoldingUsing the emergency lights on his unmarked Chevrolet Tahoe, a federal marine interdiction agent with the U.S. Customs and Border Protection (CBP) stopped the driver of a vehicle in which defendant was a passenger for driving dangerously on a public highway. After pulling the driver over, the agent waited in his truck for police officers who, upon arriving at the scene, searched the vehicle and arrested defendant for criminal possession of a weapon. The question on this appeal is whether the courts below properly relied on this Court's decision in People v. Williams, 797 N.Y.S.2d 35, 829 N.E.2d 1203 (2005), in granting defendant's motion to suppress the evidence recovered. The trial court concluded that suppression was warranted under Williams because, by activating his emergency lights to pull the driver of the vehicle over and approaching the car with the Buffalo police officer, the agent "acted under the color of law with all the accouterments of official authority and could not effect a citizen's arrest." The Court of Appeals decided that Williams is inapposite because the CBP agent who stopped defendant was not considered a federal law enforcement officer with peace officer powers pursuant to CPL §2.10 and CPL §2.15, he could not have improperly circumvented the jurisdictional limitations on the powers reserved for those members of law enforcement under CPL § 140.25. Therefore, the trial court should have denied defendant’s motion to suppress the gun found as a result of a traffic stop, called in by the agent, and the appellate court erred by affirming suppression of the evidence.

Summary of Case Context & HoldingA police officer stopped defendant's car because of a nonfunctioning center brake light. Defendant, who exhibited signs of intoxication, was given—and failed—a portable breathalyzer test. Defendant was arrested and charged with operating a motor vehicle while impaired (Vehicle and Traffic Law § 1192) and two counts of operating a motor vehicle while intoxicated. Defendant moved to suppress the evidence obtained as a result of the stop, asserting that the officer lacked probable cause to justify the seizure. The sole issue on appeal is whether the officer's belief that defendant violated the Vehicle and Traffic Law by operating a vehicle with a nonfunctioning center stop light was objectively reasonable. The Court of Appeals concluded that the officer's interpretation of the Vehicle and Traffic Law was objectively reasonable because the law mandates that motor vehicles must be equipped with at least two functioning stop lamps. Therefore, the courts below erred as a matter of law in granting defendant's suppression motion.

Summary of Case Context & HoldingThe Court of Appeals held that defendant was properly assessed points under Sex Offender Registration Act (SORA) risk assessment instrument risk factor 9, which concerns the “Number and Nature of Prior Crimes,” for his prior New Jersey conviction for lewdness. The Court of Appeals determined that reliance on the underlying conduct of a prior foreign conviction is appropriate as a matter of law for purposes of assessing points under risk factor 9 and that the New York Board of Examiners of Sex Offenders and courts should apply the “essential elements” test set forth in Matter of North v Board of Examiners of Sex Offenders of State of N.Y., 8 NY3d 745 [2007] when considering whether to assess points for the prior foreign conviction. Under that test, defendant’s New Jersey conviction was comparable to the New York offense of endangering the welfare of a child. It was therefore proper to assess him 30 points for his prior criminal history. The Court of Appeals also held that the New York Board of Examiners of Sex Offenders may rely on youthful offender adjudications and juvenile delinquency findings as "reliable indicators of wrongdoing" in connection with assessing "an offender's likelihood of re-offense and danger to public safety," even though they are not technically criminal convictions.

Summary of Case Context & HoldingA defendant's driving, appearance, and responses to questions gave an officer probable cause to arrest him on a Driving While Intoxicated. The officer asked the defendant to step out of the car and searched him, discovering a switchblade, after which the defendant was arrested. In court, the officer said he did not intend to arrest defendant until he found the switchblade. The Court of Appeals held that, although the officer hypothetically had the authority to search defendant as a search "incident to a lawful arrest," since the officer said there would not have been an arrest but for the fruits of his search, the search was not "incident" to the arrest and therefore The Court of Appeals suppressed the knife as evidence and dismissed the indictment.

Summary of Case Context & HoldingDefendant, a 17 year old, pled guilty to one count of criminal drug possession and was sentenced to five years of prison and two years of post-release supervision. Defendant appealed, arguing that the sentencing court failed to address whether he could be considered a "Youthful Offender," a determination for 16- to 19-year old in New York which carries benefits such as a vacated conviction and lesser jailtime. The Court of Appeals found that, despite the fact that defendant did not ask for a Youthful Offender determination, all there must be a Youthful Offender determination in every case where a defendant may be eligible, and that such defendant cannot waive this right via a plea deal.

Summary of Case Context & HoldingIn trial court, defendants in three cases were not allowed to cross-examine police officers regarding allegations of prior misconduct by these officers in unrelated federal lawsuits. The Court of Appeals held that there is no categorical prohibition against such cross-examination, and determination as to whether to permit such inquiries for impeachment purposes lies at the discretion of the trial court judge.

Summary of Case Context & HoldingDefendant, a noncitizen, faced several charges after attacking the mother of his children. The defendant argued that the Sixth Amendment entitled him to a jury trial given that these offenses carried the risk of deportation. The lower appeals court denied this motion and he was convicted for said deportable offenses. The Court of Appeals reversed this decision, in the first case of its kind under its jurisdiction, finding that the Sixth Amendment does indeed entitle a defendant to the right to a jury trial if indicted under deportable offenses.

Summary of Case Context & Holding17-year old defendant pled guilty to a designated class E felony sex offense, was designated a Youthful Offender, and sentenced to 10 years' probation. Class E felonies are subject to the same sentences for Youthful Offenders as others convicted of such felonies. At the time of enactment of the relevant Youthful Offenders statute, all class E felonies were subject to only 5 years probation. The statute was later updated so that designated class E felonies were subject to 10 years probation. The Defendant argued that, since the legislature did not specifically update the Youthful Offenders statute to also reflect a maximum 10 years' probation for designated class E felonies, the legislature intended for the Youthful Offenders maximum for such felonies to remain 5 years' probation. The Court of Appeals disagreed, holding that since this claim is unproven, they must rely only on text of the Youthful Offenders statute, which refers back to the amended statute, by which 10 years' probation is allowable.

Summary of Case Context & HoldingSeventeen-year-old defendant Storm Lang was charged with four felony counts of sexual abuse, and two misdemeanor counts of sexual abuse stemming from his sexual assault of three children ages 5, 7 and 12 years old. During the sentencing proceeding, the Court of Appeals decided the Youthful Offender adjudication was inappropriate and reminded Lang that he had waived his right to appeal when he had accepted his plea bargain. Lang challenged both the waiver and the denial of Youthful Offender status arguing that both were invalid and unenforceable. This Court of Appeals decided that Lang was entitled to relief because the trial court mischaracterized the appellate rights waived as encompassing not only an absolute bar to the taking of a direct appeal but also all post-conviction relief separate from the direct appeal and thus, it could not be said that their appeal waivers were knowingly and voluntarily made. However, the Court of Appeals concluded that the remainder of the waiver was valid and enforceable, foreclosing review of the Youthful Offender determination.

Summary of Case Context & HoldingDefendant was convicted of depraved indifference murder of his infant son based on both the video tape of a 9.5 hour investigation during which police falsely represented that his wife had accused him of the murder, that she would be the target of the investigation if he did not take responsibility, and that his confession would help to save his son's life, who had already died in the hospital. Defendant moved to suppress this interrogation and was denied. The Court of Appeals overturned this denial, reversed the conviction, and directed a new trial, finding that the defendant's statements were not demonstrably voluntary, as any parent would confess to a crime if they believed it would save their child's life.

Summary of Case Context & HoldingDefendant, a caregiver to a physically disabled ten-year old girl, pled guilty to a charge of reckless endangerment arising out a severe skin injury requiring skin grafts that the girl received while in the defendant's care. Following a civil jury unanimously concluding that the defendant was not at fault, as well as further evidence coming to light indicating the same, the defendant moved to vacate the judgement on a claim of "actual innocence." Focusing on matters of law rather than matters of fact, the Court of Appeals refused to allow her to vacate her guilty plea, finding that the relevant statute does not entitle a defendant who has entered in a guilty plea to move to vacate a conviction, regardless of actual innocence, unless the claim is based on DNA evidence.

Summary of Case Context & HoldingAfter defendant struck and killed a pedestrian, her family contacted a lawyer who instructed law enforcement not to question or test his client. Defendant consented to a breathalyzer test at the same time, without being informed of the attorney's communication. Based on prior case law, the Court of Appeals reaffirms that suspected drunk drivers have time-limited rights to seek legal assistance before chemical testing, and this right cannot be waived prior to the police making the accused aware that a lawyer has made contact on the accused's behalf, regardless of whether the accused requested this lawyer.

Summary of Case Context & HoldingIn 2014, defendant, was charged with committing various crimes against a 10-year-old child and pleaded guilty to sexual abuse in the first degree. Defendant was initially placed on interim probation. Due to defendant's subsequent arrest on other charges stemming from conduct occurring after his plea, defendant's probation was revoked and he was sentenced to a three-year term of imprisonment. This Court of Appeals held that the Appellate Division had authority to reverse a county court order that designated defendant a level three sex offender under the Sex Offender Registration Act, based on a risk factor point assessment. In the absence of an erroneous ruling or any applicable statutory or other jurisdictional limitation on the Appellate Division’s authority, the Court of Appeals declined to restrain the Appellate Division from remitting the country order.

Summary of Case Context & Holding16-year old defendant was charged with second degree murder for shooting a teenaged bystander during an argument, and spent six years in prison before pleading guilty. During this time, the prosecution sought cooperation against the defendant by his co-defendant through various means, then faced administrative delays in beginning the trial. The Court of Appeals held that, despite the absence of bad faith for these delays on behalf of the government, the defendant's imprisonment for such a long time violated his right to a speedy trial, and dismissed his indictment.

Summary of Case Context & HoldingIn 2016, the New York City Water Board -- which collects revenues to keep the City's water and sewer systems financially self-sustaining -- approved a 2.1% rate increase, a one-time bill credit of $183 for the fiscal year to all account holders belonging in a particular tax class, as well as assistance programs for multi-unit apartments, seniors and low-income households and a low-consumption rate freeze. The City of New York also announced it would temporarily forbear collecting rents from the Water Board and provided that the savings from the rent forbearance would be passed on to all account holders. Petitioners, which included various landlords not eligible for the bill credit and not-for-profit assistance, commenced an action against the Water Board and New York Department of Environmental Protection (DEP), arguing the Water Board's determinations were irrational, arbitrary, and capricious and exceeded the Board's authority. The Court of Appeals held that the governing statutes provide that water and sewer rates may be determined in accordance with public policy goals, not just economic ones. Specifically, the Court found the respondents' decision to allocate the relatively modest gain from the rent forbearance so as to be meaningful to a very large category of ratepayer, without requiring a complex application process, was not irrational. Thus, the Court of Appeals could not say the respondents' actions were utterly arbitrary or unsupported by rational goals.

Summary of Case Context & HoldingIn 2006, the state's Department of Environmental Conservation (DEC) and the New York State Office of Parks, Recreation, and Historic Preservation prepared a plan to create a 27-mile system of snowmobile trails between communities in the Adirondack Park Forest Preserve. This plan would require the cutting and removal of thousands of trees, grading and leveling, and the removal of rocks and other natural components from the Forest Preserve to create such snowmobile paths. Plaintiff brought an action alleging the construction of the trails was in violation of the "forever wild" provision (article XIV) of the New York Constitution. This constitutional provision mandated that protected Forest Preserve lands "shall be forever kept as wild forest lands" with the intent of ending commercial destruction and despoliation of the soil and trees and protecting the state's watershed. The Court of Appeals ruled that the level of tree cutting needed to construct these trails exceeded the level of tree cutting permitted by prior Court decisions regarding compliance with article XIV. Accordingly, the Court of Appeals held that the planned snowmobile trails violated the State Constitution's "forever wild" provision and that construction of these trails could only be accomplished with a constitutional amendment.