In People v. Taylor, the defendant was convicted in 2013 of second-degree assault and fourth-degree criminal possession of a weapon following a fight outside a concert venue, with the prosecution relying heavily on a cabdriver's eyewitness account. After his conviction was affirmed on direct appeal, he moved under CPL 440.10 to vacate the judgment, alleging ineffective assistance of trial counsel for failing to impeach the cabdriver with a prior inconsistent statement, request a lesser-included offense, object to an Allen charge, and properly seek a justification instruction under Penal Law § 35.05. County Court denied the motion without a hearing, ruling that all claims were procedurally barred because they could have been raised on direct appeal. The Appellate Division reversed, holding that at least some of the ineffective-assistance claims rested on matters outside the trial record and that counsel's documented failures—particularly in impeachment and articulating the justification defense—deprived the defendant of meaningful representation, warranting a new trial.
In this case, defendant Daniel Taylor was convicted in 2013 of assault in the second degree and criminal possession of a weapon in the fourth degree arising from a fight outside a concert venue. He later moved under CPL 440.10 to vacate the judgment, alleging ineffective assistance of counsel on several grounds, including failure to impeach a key prosecution witness with a prior inconsistent statement and failure to properly request a jury instruction on the defense of justification. County Court denied the motion without a hearing, ruling that the claims were procedurally barred because they could have been raised on direct appeal. The Appellate Division reversed, holding that at least some of the ineffective-assistance claims depended on facts outside the original record and could not have been raised on appeal, and that counsel's deficiencies deprived defendant of meaningful representation; it therefore granted the motion and ordered a new trial.
This case arose from a personal injury lawsuit in which the plaintiff settled his claims against his employer for $3.25 million plus the employer's agreement to satisfy an outstanding workers' compensation lien of about $264,000. After the employer paid the plaintiff but delayed satisfying the lien, the plaintiff sought a judgment including interest, costs, and disbursements under CPLR 5003-a for the full settlement amount. The trial court denied that request, holding that the statute applies only to sums payable directly to the plaintiff. On appeal, the court affirmed, ruling that payments owed to a third-party lienholder do not qualify as sums due to the plaintiff under the statute's plain language and legislative history, which focuses on prompt payment to settling plaintiffs themselves.
In People v. Spratley, the defendant was indicted on charges including attempted murder and assault as hate crimes after an incident in which he allegedly used racial slurs against an African-American victim before shooting him. The County Court dismissed the hate crime counts, finding insufficient evidence that the acts were committed because of the victim's race. On appeal, the Appellate Division modified the order, reinstating the hate crime counts for attempted murder and assault because the grand jury evidence—including repeated racial epithets and a prior statement of racial animus—provided prima facie proof of the required motive, while upholding dismissal of the firearm count as it is not a specified offense under the hate crimes statute. The court reasoned that the evidence, viewed in the light most favorable to the People, allowed a rational inference that the crimes were motivated in whole or substantial part by the victim's race.
In People v. Spratley, the defendant faced charges including attempted murder and assault as hate crimes after allegedly shooting an African-American victim outside a bar while using multiple racial slurs. County Court dismissed the hate crime counts, finding insufficient evidence that the acts were committed in whole or substantial part because of the victim's race. The Appellate Division modified the order by reinstating the attempted murder and assault hate crime counts, holding that grand jury evidence of repeated racial epithets directed at the victim and a prior statement that the defendant hated black people provided prima facie proof of the required motive. The court also upheld dismissal of the criminal use of a firearm hate crime count because that offense is not a specified offense under the hate crimes statute.
The case involved a challenge by health care provider associations to regulations issued by the New York Department of Health under Executive Order 38 that limited administrative expenses and executive compensation for entities receiving state funds or state-authorized payments, primarily through Medicaid programs. The Supreme Court partially dismissed the petitions seeking to invalidate the rules, and the Appellate Division reviewed whether the regulations exceeded agency authority, complied with statutory requirements, and satisfied separation-of-powers standards under the Boreali test. The court upheld the hard cap restricting use of state funds for administrative costs and compensation above $199,000, finding it within DOH's expertise and legislative authorization, while invalidating the soft cap that extended limits to non-state funding sources as an improper policy choice lacking sufficient statutory grounding. The decision emphasized that the rules aimed to direct taxpayer dollars toward direct care rather than overhead, following extensive public comment and revisions.