Justia Criminal Law Opinion Summaries

After a jury trial, Defendant was convicted of conspiracy in the sixth degree and two counts of official misconduct. On appeal, the Appellate Division affirmed Defendant’s convictions. The Court of Appeals affirmed the order of the Appellate Division in all respects, holding (1) the jury could have rationally concluded that there was legally sufficient evidence to convict Defendant of official misconduct under a theory of malfeasance; (2) the jury could have rationally concluded that the elements of official misconduct by nonfeasance were established; and (3) there was legally sufficient evidence to support Defendant’s conspiracy conviction. View "People v. Flanagan" on Justia Law

After a jury trial, Defendant was found guilty of manslaughter in the first degree. Defendant appealed, arguing, inter alia, that the trial court erred by precluding defense counsel from questioning prospective jurors during voir dire as to their ability to follow and apply the law regarding the use of involuntary statements at trial. The Appellate Division affirmed. The Court of Appeals reversed, holding that, under the circumstances of this case, the trial court abused its discretion in prohibiting defense counsel from questioning prospective jurors with respect to their views on involuntary confessions. View "People v. Miller" on Justia Law

Defendant, a dark-complexioned African-American male, was charged with one count of robbery in the first degree and two counts of robbery in the second decree. During voir dire, the prosecutor used a peremptory strike to exclude a dark-complexioned Indian-American woman. Defendant challenged the prosecutor’s use of peremptory strikes to exclude dark-colored women. The courts below held that Defendant failed to make a prima facie showing of discrimination regarding the prosecutor’s use of peremptory strikes. The Court of Appeals reversed, holding (1) skin color of a prospective juror is a cognizable classification to challenge a prosecutor’s use of peremptory strikes under Batson v. Kentucky; and (2) because defense counsel met her prima facie burden by alleging that the prosecutor was excluding dark-colored prospective female jurors, and the prosecutor did not give a non-discriminatory reason for excluding the dark-complexioned Indian-American woman, the trial court committed reversible error by not seating the juror. View "People v. Bridgeforth" on Justia Law

After a jury trial, Defendant was convicted of two counts of coercion in the first degree. The Appellate Division affirmed. Defendant appealed, arguing (1) the court, rather than the jury, made a factual determination regarding the seriousness of his conduct when it declined to instruct the jury on the lesser-included offense of coercion in the second degree in violation of the rule set out in Apprendi v. New Jersey; and (2) the trial court erred in declining to instruct the jury on the lesser-included offense of coercion in the second degree. The Court of Appeals affirmed, holding (1) Defendant’s first argument on appeal was unpreserved for appellate review; (2) the facts of this case did not warrant the lesser included charge; and (3) the trial court did not violate Defendant’s constitutional right to represent himself by ruling that he forfeited his right to proceed pro se during pre-trial proceedings. View "People v. Finkelstein" on Justia Law

After a jury trial, Defendant was convicted of second-degree burglary and robbery. Defendant appealed, arguing that the trial court erred by admitting subscriber information in prepaid cell phone records as nonhearsay evidence located within a business record. The Appellate Division affirmed, concluding that the subscriber information did not constitute assertions of fact but was properly admitted as circumstantial evidence of Defendant’s identity as the purchaser of the phone. The Court of Appeals affirmed, holding that the lower court properly determined that the subscriber information was properly admitted for a limited, nonhearsay purpose and was not introduced for the truth of the matters asserted herein. View "People v. Patterson" on Justia Law

After a jury trial, Defendant was convicted of criminal possession of a weapon in the second degree. Defendant was sentenced as a persistent violent felony offender to twenty years to life in prison. The Appellate Division vacated Defendant’s sentence and remitted for sentencing because the sentencing court improperly considered as a basis for sentencing a crime that was dismissed for lack of legally sufficient evidence. At resentencing, Supreme Court again sentenced Defendant to an indeterminate term of twenty years to life. Defendant appealed, arguing that the court again improperly considered the dismissed counts and that his counsel had been ineffective for failing to object to the court’s failure to impose a lesser sentence than it originally imposed. The Appellate Division affirmed. The Court of Appeals affirmed, holding (1) the sentencing court’s reimposition of an identical sentence did not indicate that it relied on improper criteria; and (2) defense counsel’s failure to challenge Defendant’s resentencing did not render his performance constitutionally deficient. View "People v. Flowers" on Justia Law

After a jury trial, Defendant was convicted of murder in the second degree and assault in the second degree. The Appellate Division affirmed, concluding, as relevant to this appeal, that defense counsel was not ineffective for either failing to advance a justification defense that would have been inconsistent with Defendant’s theory of misidentification or for failing to object to a courtroom closure given the law at the time. The Court of Appeals affirmed, holding that counsel was not ineffective for pursuant a misidentification defense at Defendant’s behest rather than offering a defense of justification, and counsel adequately protected Defendant’s right to a public trial. View "People v. Clark" on Justia Law

Defendant was charged with murder in the second degree and other crimes. On the second day of deliberations, the jury sent out a note stating that it was deadlocked. The trial court proceeded by repeating its final instruction concerning the jury’s duty to deliberate. Two hours later, the jury announced that it had come to a verdict. The jury found Defendant not guilty of murder but guilty of manslaughter and criminal possession of a weapon. It was not a unanimous verdict. The trial judge refused to accept the verdict and ordered that jurors resume deliberations in an attempt to reach a unanimous verdict. After further deliberations, the jury reached the same verdict, only this time, polling was unanimous. The Appellate Division affirmed. Defendant appealed, arguing, inter alia, that the trial court’s supplemental instruction in response to the defective verdict was coercive. The Court of Appeals affirmed, holding (1) under the circumstances, the trial court’s instructions were not coercive and, accordingly, did not deprive Defendant of a fair trial; and (2) Defendant’s remaining allegations of error were without merit. View "People v. Morgan" on Justia Law

In each of these three appeals, Defendants moved to dismiss the accusatory instrument on speedy trial grounds, asserting that the People’s off-calendar statements of readiness were illusory because the People were not, in fact, ready for trial at the next court appearance. At issue before the Court of Appeals was whether, in the event of a change in the People’s readiness status, the People or the defendant have the burden of showing that a previously filed off-calendar statement of readiness is illusory. The Supreme Court held (1) the People’s previously off-calendar statement of readiness if presumed truthful and accurate; and (2) a defendant can rebut this presumption by demonstrating that the People were not, in fact, ready at the time the statement was filed. View "People v. Brown" on Justia Law

Defendant was identified as a suspect in several gunpoint robberies and was included in lineup identification procedures. Defendant moved to suppress the identification procedures, arguing that the lineups were unduly suggestive. Supreme Court granted the motion with respect to two victims but denied it with respect to the other two victims. After a trial, the jury convicted Defendant of the counts with respect to two victims. The Appellate Division affirmed. At issue in this case was whether the lineups were unduly suggestive because Defendant had a different hairstyle than some or all of the fillers. The Court of Appeals reversed and granted Defendant’s motion to suppress the line-up identifications, concluding that there was no record support for the lower courts’ denial of suppression for the latter two victims, as a witness’s failure to mention a distinctive feature in his or her initial description is not necessarily the determinative factor in assessing a lineup’s suggestivity, and therefore, both lineups should have been suppressed. View "People v. Perkins" on Justia Law