ex post facto clause (New York) · Go Syfert
← New York issues

ex post facto clause in New York

61 New York opinions name it 8 courts 1939–2023 1 in the last five years

The cases below were cited by New York courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (25)

CaseFollowedCited
Robinson v. Bennettgreen
nyappdiv · 2002 · cited in 4 New York opinions naming this issue, 2007–2014
2 sentences

2014It has been held that the ex post facto doctrine does not apply to administrative regulations (Matter of Robinson v Bennett, 300 AD2d 715, 716 [3d Dept 2002]).

2014In addition, it has been held that the ex post facto doctrine does not apply to administrative regulations (see Matter of Robinson v Bennett, 300 AD2d 715, 716 [3d Dept 2002]; Matter of Suce v Taylor, 37 AD3d 886, 887 [3d Dept 2007]).

44
Doe v. Patakigreen
ca2 · 1997 · cited in 3 New York opinions naming this issue, 2013–2023
2 sentences

2013In Doe v Pataki, the Second Circuit rejected the ex post facto challenge to SORA’s 90-day in-person reporting requirement for certain high risk offenders, stating, “We agree with the [djistrict [cjourt that the registration requirements of the SORA do not impose punishment upon the plaintiffs” (120 F3d at 1284; see also Manzullo v People of New York, 2010 WL 1292302 , *8, 2010 US Dist LEXIS 32089 , *22 [ED NY 2010] [denying habeas relief to petitioner on the ground that “both the registration and notification provisions of (Megan’s Law) (do) not constitute punishment for the purposes of the Ex

2013In Doe v Pataki, the Second Circuit rejected the ex post facto challenge to SORA’s 90-day in-person reporting requirement for certain high risk offenders, stating, “We agree with the [djistrict [cjourt that the registration requirements of the SORA do not impose punishment upon the plaintiffs” (120 F3d at 1284; see also Manzullo v People of New York, 2010 WL 1292302 , *8, 2010 US Dist LEXIS 32089 , *22 [ED NY 2010] [denying habeas relief to petitioner on the ground that “both the registration and notification provisions of (Megan’s Law) (do) not constitute punishment for the purposes of the Ex

33
People ex rel. Suce v. Taylorgreen
nyappdiv · 2007 · cited in 2 New York opinions naming this issue, 2009–2014
2 sentences

2014In addition, it has been held that the ex post facto doctrine does not apply to administrative regulations (see Matter of Robinson v Bennett, 300 AD2d 715, 716 [3d Dept 2002]; Matter of Suce v Taylor, 37 AD3d 886, 887 [3d Dept 2007]).

2009Nor do we find that petitioner was excused from doing so based upon his “mere assertion that a constitutional right is involved” (Matter of Valvano v Jones, 122 AD2d 336, 336 [1986], quoting Matter of Pfaff v Columbia-Greene Community Coll., 99 AD2d 887, 888 [1984]; see Matter of Roberts v Coughlin, 165 AD2d 964, 966 [1990]) inasmuch as his substantive claim—that the application of the 1997 amendments to 9 NYCRR 8005.20 (c) and (d) violated the ex post facto doctrine because he was sentenced prior to the promulgation of the amendments—has been previously rejected by this Court (see Matter of S

22
Smith v. Doegreen
scotus · 2003 · cited in 4 New York opinions naming this issue, 2011–2023
2 sentences

2023The “most significant factor” in the ex post facto analysis is the fourth, which requires consideration of whether the statute has a “rational connection to a nonpunitive purpose” (Smith, 538 US at 102 ) and here, weighs heavily against petitioner.

2023The Supreme Court applied this “intent-effects test”—originally devised to evaluate federal penal and regulatory laws—in Smith v Doe, to uphold Alaska’s registration-and-notification statute—which did not include SARA-like restrictions— against an ex post facto challenge ( 538 US at 105-106 ).4 At the first step, if the Court 4 Five years after the Court’ decision in Smith, the Alaska Supreme Court invalidated retroactive application of the statute under the Ex Post Facto Clause of the Alaska State - 10 - - 11 - No. 47 determines that the legislature intended to impose punishment the inquiry e

14
Beazell v. Ohiogreen
scotus · 1925 · cited in 4 New York opinions naming this issue, 1978–1996
2 sentences

1996(US Const, art I, § 10, cl [1].) In Collins v Youngblood ( 497 US 37 [1990]), the United States Supreme Court refined its analysis of the ex post facto clause, essentially by returning it to parameters defined by ancient principles which reflect "the original understanding of Ex Post Facto Clause” (supra, at 43, citing Beazell v Ohio, 269 US 167, 169-170 [1925]; Caldor v Bull, 3 Dali 386, 390 [1798]).

1988The modern formulation of the ex post facto rule may be found in the three leading Supreme Court cases, Weaver v Graham ( 450 US 24 ), Dobbert v Florida ( 432 US 282 ) and Beazell v Ohio ( 269 US 167 ).

14
Dobbert v. Floridagreen
scotus · 1977 · cited in 3 New York opinions naming this issue, 1985–2020
2 sentences

2020Accordingly, there was no Ex Post Facto violation because the statutory change at issue "had no effect on the defendant" ( Dobbert v Florida , 432 US 282, 300 [1977]).

1988The modern formulation of the ex post facto rule may be found in the three leading Supreme Court cases, Weaver v Graham ( 450 US 24 ), Dobbert v Florida ( 432 US 282 ) and Beazell v Ohio ( 269 US 167 ).

13
Weaver v. Grahamgreen
scotus · 1981 · cited in 2 New York opinions naming this issue, 1988–2023
2 sentences

2023While an individual’s liberty interest may indeed be diminished during those periods, that point weighs more significantly in a substantive due process inquiry than an Ex Post Facto challenge (see Weaver v Graham, 450 US 24, 29-30 [1981] [“Evaluating whether a right has vested is important for claims under the . . .

2023While an individual’s liberty interest may indeed be diminished during those periods, that point weighs more significantly in a substantive due process inquiry than an Ex Post Facto challenge (see Weaver v Graham, 450 US 24, 29-30 [1981] [“Evaluating whether a right has vested is important for claims under the . . .

12
Seling v. Younggreen
scotus · 2001 · cited in 2 New York opinions naming this issue, 2002–2016
2 sentences

2016Petitioner, himself, acknowledges that there can be no as-applied challenge based on the Ex Post Facto clause ( see Selig v Young at 263).

2002If the statute simply creates a civil remedy and not criminal punishment there is no ex post facto violation (Seling v Young, 531 US 250 ).

12
Flemming v. Nestorgreen
scotus · 1960 · cited in 1 New York opinions naming this issue, 2023–2023
1 sentence

2023As the Supreme Court has observed, for ex post facto purposes, “the punishment of imprisonment . . . is the paradigmatic affirmative disability or restraint” (Smith, 538 US at 100 ); see also Flemming v Nestor, 363 US 603, 617 [1960] [referring to “the infamous punishment of imprisonment” in an ex post facto case]).

11
Kennedy v. Mendoza-Martinezgreen
scotus · 1963 · cited in 1 New York opinions naming this issue, 2023–2023
1 sentence

2023The most relevant in an ex post facto analysis as “whether, in its necessary operation, the regulatory scheme: has been regarded in our history and traditions as a punishment; imposes an affirmative disability or restraint; promotes the traditional aims of punishment; has a rational connection to a nonpunitive purpose; or is excessive with respect to this purpose” (id., citing Kennedy v Mendoza-Martinez, 372 US 144, 168-169 [1963]).

11
United States v. Rossgreen
scotus · 1982 · cited in 1 New York opinions naming this issue, 2016–2016
11
People v. Fostergreen
nyappdiv · 2011 · cited in 1 New York opinions naming this issue, 2014–2014
11
People v. Hallgreen
nyappdiv · 2014 · cited in 1 New York opinions naming this issue, 2014–2014
11
People v. Keeblergreen
nyappdiv · 2005 · cited in 1 New York opinions naming this issue, 2014–2014
11
Olshan v. Merensgreen
nyappdiv · 1977 · cited in 1 New York opinions naming this issue, 2013–2013
11
North v. Board of Examinersgreen
ny · 2007 · cited in 1 New York opinions naming this issue, 2010–2010
11
People v. Knoxgreen
ny · 2009 · cited in 1 New York opinions naming this issue, 2010–2010
11
Pfaff v. Columbia-Greene Community Collegegreen
nyappdiv · 1984 · cited in 1 New York opinions naming this issue, 2009–2009
11
Valvano v. Jonesgreen
nyappdiv · 1986 · cited in 1 New York opinions naming this issue, 2009–2009
11
Roberts v. Coughlingreen
nyappdiv · 1990 · cited in 1 New York opinions naming this issue, 2009–2009
11
V & A Towing, Inc. v. City of New Yorkgreen
nyappdiv · 1993 · cited in 1 New York opinions naming this issue, 2007–2007
11
Scarola v. Goordgreen
nyappdiv · 1999 · cited in 1 New York opinions naming this issue, 2007–2007
11
Hopt v. People of Territory of Utahgreen
scotus · 1884 · cited in 1 New York opinions naming this issue, 2000–2000
11
Hamm v. Latessa, MCIgreen
ca1 · 1995 · cited in 1 New York opinions naming this issue, 1998–1998
11
Santiago v. Recoregreen
nyappdiv · 1997 · cited in 1 New York opinions naming this issue, 1997–1997
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in New York. Read the followed side critically anyway.

Also cited on this issue (55)

CaseCitedYears
People v. Aiello green
nyappdiv · 1983
2 sentences

1984We have previously held that under such circumstances the second violent felony offender statutes do not violate the ex post facto clause of sections 9 and 10 of article I of the United States Constitution (see People v Barfour, 95 AD2d 812 ; People v Aiello, 93 AD2d 864 ).

1984We note that the persistent violent felony offender statutes (Penal Law, §§ 70.02, 70.04,70.08), as applied to defendant, do not violate the ex post facto clause of section 10 of article I of the United States Constitution (see People v Barbour, 96 AD2d 842 ; People v Balfour, 95 AD2d 812 ; People v Aiello, 93 AD2d 864 , mot for lv to app granted 60 NY2d 822 ).

41983–1984
People ex rel. Persing v. Lacy green
nyappdiv · 2000
2 sentences

2002Persing v Lacy, 276 AD2d 815, 816 ), have been examined and found to be unpersuasive.

2001Persing v Lacy, 276 AD2d 815 ).

32001–2002
In re the Claim of Nailos green
nyappdiv · 1995
2 sentences

1999Participation in the merit time allowance program is a privilege, not a right (see, Correction Law § 803 [4]), and, accordingly, the ex post facto doctrine is inapplicable (see, Matter of Dixon v Struna, 244 AD2d 827 , lv denied 91 NY2d 810 ; Matter of McCormack v Posillico, 213 AD2d 913 ).

1997Moreover, because participation in a temporary work release program is a privilege, rather than a right, the ex post facto doctrine is inapplicable (see, Matter of Rand v Coughlin, 229 AD2d 803 ; Matter of McCormack v Posillico, 213 AD2d 913 ).

31996–1999
Doe v. Raemisch green
wied · 2012
2 sentences

2013These provisions created new crimes; they did not increase the punishment for Plaintiffs’ previous offenses” (Doe v Raemisch, 895 F Supp 2d at 908 ; see also People v McFarland, 29 Misc 3d 1206[A] , 2010 NY Slip Op 51705[U] [Sup Ct, NY County 2010]).

2013These provisions created new crimes; they did not increase the punishment for Plaintiffs’ previous offenses” (Doe v Raemisch, 895 F Supp 2d at 908 ; see also People v McFarland, 29 Misc 3d 1206[A] , 2010 NY Slip Op 51705[U] [Sup Ct, NY County 2010]).

22013–2013
Voo Doo Contracting Corp. v. L & J Plumbing & Heating Co. green
nyappdiv · 1999
2 sentences

2002Kelly v New York State Div. of Parole, 264 AD2d 361, 362 ; People ex rel.

2000Kelly v New York State Div. of Parole, 264 AD2d 361 ; People ex rel.

22000–2002
People v. Green green
ny · 1990
2 sentences

2000Claims that are foreclosed by a guilty plea have, for example, included pre-indictment prosecutorial misconduct (People v Di Raffaele, 55 NY2d 234 , supra)-, selective prosecution (People v Rodriguez, 55 NY2d 776 ); failure to provide CPL 710.30 notice (People v Taylor, 65 NY2d 1 , supra)-, the statutory right to a speedy trial (People v Friscia, 51 NY2d 845 ; People v Brothers, 50 NY2d 413 ); the denial of an application for leave to file a late motion to suppress (People v Petgen, 55 NY2d 529 ); transactional immunity (People v Flihan, 73 NY2d 729 ); the exercise of alleged discriminatory pe

1992Hence, the forfeiture occasioned by a guilty plea extends to claims premised upon, inter alia, a failure to provide CPL 710.30 notice (see, People v Taylor, 65 NY2d 1, supra), the statutory right to a speedy trial (see, People v O’Brien, 56 NY2d 1009 ; People v Howe, 56 NY2d 622 ), the denial of an application for leave to file a late motion to suppress (see, People v Petgen, 55 NY2d 529), whether a proper foundation was laid regarding the accuracy of a blood alcohol test (see, People v Campbell, 73 NY2d 481 ), transactional immunity (see, People v Flihan, 73 NY2d 729 ), the exercise of allege

21992–2000
People v. Latzer neutral
ny · 1988
2 sentences

2000Claims that are foreclosed by a guilty plea have, for example, included pre-indictment prosecutorial misconduct (People v Di Raffaele, 55 NY2d 234 , supra)-, selective prosecution (People v Rodriguez, 55 NY2d 776 ); failure to provide CPL 710.30 notice (People v Taylor, 65 NY2d 1 , supra)-, the statutory right to a speedy trial (People v Friscia, 51 NY2d 845 ; People v Brothers, 50 NY2d 413 ); the denial of an application for leave to file a late motion to suppress (People v Petgen, 55 NY2d 529 ); transactional immunity (People v Flihan, 73 NY2d 729 ); the exercise of alleged discriminatory pe

1992Hence, the forfeiture occasioned by a guilty plea extends to claims premised upon, inter alia, a failure to provide CPL 710.30 notice (see, People v Taylor, 65 NY2d 1, supra), the statutory right to a speedy trial (see, People v O’Brien, 56 NY2d 1009 ; People v Howe, 56 NY2d 622 ), the denial of an application for leave to file a late motion to suppress (see, People v Petgen, 55 NY2d 529), whether a proper foundation was laid regarding the accuracy of a blood alcohol test (see, People v Campbell, 73 NY2d 481 ), transactional immunity (see, People v Flihan, 73 NY2d 729 ), the exercise of allege

21992–2000
People v. Rodriguez green
ny · 1981
2 sentences

2000Claims that are foreclosed by a guilty plea have, for example, included pre-indictment prosecutorial misconduct (People v Di Raffaele, 55 NY2d 234 , supra)-, selective prosecution (People v Rodriguez, 55 NY2d 776 ); failure to provide CPL 710.30 notice (People v Taylor, 65 NY2d 1 , supra)-, the statutory right to a speedy trial (People v Friscia, 51 NY2d 845 ; People v Brothers, 50 NY2d 413 ); the denial of an application for leave to file a late motion to suppress (People v Petgen, 55 NY2d 529 ); transactional immunity (People v Flihan, 73 NY2d 729 ); the exercise of alleged discriminatory pe

1992Hence, the forfeiture occasioned by a guilty plea extends to claims premised upon, inter alia, a failure to provide CPL 710.30 notice (see, People v Taylor, 65 NY2d 1, supra), the statutory right to a speedy trial (see, People v O’Brien, 56 NY2d 1009 ; People v Howe, 56 NY2d 622 ), the denial of an application for leave to file a late motion to suppress (see, People v Petgen, 55 NY2d 529), whether a proper foundation was laid regarding the accuracy of a blood alcohol test (see, People v Campbell, 73 NY2d 481 ), transactional immunity (see, People v Flihan, 73 NY2d 729 ), the exercise of allege

21992–2000
People ex rel. Gaito v. Couture green
nyappdiv · 2000
2 sentences

2000Gaito v Couture, 269 AD2d 709, 710 , lv denied 95 NY2d 754 ; People ex rel.

2000Gaito v Couture, 269 AD2d 709, 710 , lv denied 95 NY2d 754 ; People ex rel.

22000–2000
People v. Thomas green
ny · 1981
2 sentences

2000Claims that are foreclosed by a guilty plea have, for example, included pre-indictment prosecutorial misconduct (People v Di Raffaele, 55 NY2d 234 , supra)-, selective prosecution (People v Rodriguez, 55 NY2d 776 ); failure to provide CPL 710.30 notice (People v Taylor, 65 NY2d 1 , supra)-, the statutory right to a speedy trial (People v Friscia, 51 NY2d 845 ; People v Brothers, 50 NY2d 413 ); the denial of an application for leave to file a late motion to suppress (People v Petgen, 55 NY2d 529 ); transactional immunity (People v Flihan, 73 NY2d 729 ); the exercise of alleged discriminatory pe

1992Hence, the forfeiture occasioned by a guilty plea extends to claims premised upon, inter alia, a failure to provide CPL 710.30 notice (see, People v Taylor, 65 NY2d 1, supra), the statutory right to a speedy trial (see, People v O’Brien, 56 NY2d 1009 ; People v Howe, 56 NY2d 622 ), the denial of an application for leave to file a late motion to suppress (see, People v Petgen, 55 NY2d 529), whether a proper foundation was laid regarding the accuracy of a blood alcohol test (see, People v Campbell, 73 NY2d 481 ), transactional immunity (see, People v Flihan, 73 NY2d 729 ), the exercise of allege

21992–2000
People v. Di Raffaele green
ny · 1982
2 sentences

2000Claims that are foreclosed by a guilty plea have, for example, included pre-indictment prosecutorial misconduct (People v Di Raffaele, 55 NY2d 234 , supra)-, selective prosecution (People v Rodriguez, 55 NY2d 776 ); failure to provide CPL 710.30 notice (People v Taylor, 65 NY2d 1 , supra)-, the statutory right to a speedy trial (People v Friscia, 51 NY2d 845 ; People v Brothers, 50 NY2d 413 ); the denial of an application for leave to file a late motion to suppress (People v Petgen, 55 NY2d 529 ); transactional immunity (People v Flihan, 73 NY2d 729 ); the exercise of alleged discriminatory pe

1992Hence, the forfeiture occasioned by a guilty plea extends to claims premised upon, inter alia, a failure to provide CPL 710.30 notice (see, People v Taylor, 65 NY2d 1, supra), the statutory right to a speedy trial (see, People v O’Brien, 56 NY2d 1009 ; People v Howe, 56 NY2d 622 ), the denial of an application for leave to file a late motion to suppress (see, People v Petgen, 55 NY2d 529), whether a proper foundation was laid regarding the accuracy of a blood alcohol test (see, People v Campbell, 73 NY2d 481 ), transactional immunity (see, People v Flihan, 73 NY2d 729 ), the exercise of allege

21992–2000
People v. Petgen green
ny · 1982
2 sentences

2000Claims that are foreclosed by a guilty plea have, for example, included pre-indictment prosecutorial misconduct (People v Di Raffaele, 55 NY2d 234 , supra)-, selective prosecution (People v Rodriguez, 55 NY2d 776 ); failure to provide CPL 710.30 notice (People v Taylor, 65 NY2d 1 , supra)-, the statutory right to a speedy trial (People v Friscia, 51 NY2d 845 ; People v Brothers, 50 NY2d 413 ); the denial of an application for leave to file a late motion to suppress (People v Petgen, 55 NY2d 529 ); transactional immunity (People v Flihan, 73 NY2d 729 ); the exercise of alleged discriminatory pe

1992Hence, the forfeiture occasioned by a guilty plea extends to claims premised upon, inter alia, a failure to provide CPL 710.30 notice (see, People v Taylor, 65 NY2d 1, supra), the statutory right to a speedy trial (see, People v O’Brien, 56 NY2d 1009 ; People v Howe, 56 NY2d 622 ), the denial of an application for leave to file a late motion to suppress (see, People v Petgen, 55 NY2d 529), whether a proper foundation was laid regarding the accuracy of a blood alcohol test (see, People v Campbell, 73 NY2d 481 ), transactional immunity (see, People v Flihan, 73 NY2d 729 ), the exercise of allege

21992–2000
People v. Flihan green
ny · 1988
2 sentences

2000Claims that are foreclosed by a guilty plea have, for example, included pre-indictment prosecutorial misconduct (People v Di Raffaele, 55 NY2d 234 , supra)-, selective prosecution (People v Rodriguez, 55 NY2d 776 ); failure to provide CPL 710.30 notice (People v Taylor, 65 NY2d 1 , supra)-, the statutory right to a speedy trial (People v Friscia, 51 NY2d 845 ; People v Brothers, 50 NY2d 413 ); the denial of an application for leave to file a late motion to suppress (People v Petgen, 55 NY2d 529 ); transactional immunity (People v Flihan, 73 NY2d 729 ); the exercise of alleged discriminatory pe

1992Hence, the forfeiture occasioned by a guilty plea extends to claims premised upon, inter alia, a failure to provide CPL 710.30 notice (see, People v Taylor, 65 NY2d 1, supra), the statutory right to a speedy trial (see, People v O’Brien, 56 NY2d 1009 ; People v Howe, 56 NY2d 622 ), the denial of an application for leave to file a late motion to suppress (see, People v Petgen, 55 NY2d 529), whether a proper foundation was laid regarding the accuracy of a blood alcohol test (see, People v Campbell, 73 NY2d 481 ), transactional immunity (see, People v Flihan, 73 NY2d 729 ), the exercise of allege

21992–2000
People v. Miller green
nyappdiv · 1980
2 sentences

1995Although it is well settled that the ex post facto doctrine does not apply to the temporary release program (see, e.g., People v Miller, 79 AD2d 687, 688 , cert denied 452 US 919 ), at least one Federal court has held that while the State can change its law regarding the eligibility of inmates already in the program, "a Due Process hearing is required before inmates already participating in or approved for the program may be removed * * * Due Process requires a reevaluation by the commissioner of each participating inmates’ eligibility in light of the threat that the inmate presents to the sec

1995Participation in the temporary work release program is a privilege, not a right (Correction Law § 855 [9]) and, therefore, the ex post facto doctrine is inapplicable (People v Miller, 79 AD2d 687, 688 , cert denied 452 US 919 ).

21995–1995
Hinkle v. Virginia green
scotus · 1981
2 sentences

1995Although it is well settled that the ex post facto doctrine does not apply to the temporary release program (see, e.g., People v Miller, 79 AD2d 687, 688 , cert denied 452 US 919 ), at least one Federal court has held that while the State can change its law regarding the eligibility of inmates already in the program, "a Due Process hearing is required before inmates already participating in or approved for the program may be removed * * * Due Process requires a reevaluation by the commissioner of each participating inmates’ eligibility in light of the threat that the inmate presents to the sec

1995Participation in the temporary work release program is a privilege, not a right (Correction Law § 855 [9]) and, therefore, the ex post facto doctrine is inapplicable (People v Miller, 79 AD2d 687, 688 , cert denied 452 US 919 ).

21995–1995
People v. Balfour green
nyappdiv · 1983
2 sentences

1984We have previously held that under such circumstances the second violent felony offender statutes do not violate the ex post facto clause of sections 9 and 10 of article I of the United States Constitution (see People v Barfour, 95 AD2d 812 ; People v Aiello, 93 AD2d 864 ).

1984We note that the persistent violent felony offender statutes (Penal Law, §§ 70.02, 70.04,70.08), as applied to defendant, do not violate the ex post facto clause of section 10 of article I of the United States Constitution (see People v Barbour, 96 AD2d 842 ; People v Balfour, 95 AD2d 812 ; People v Aiello, 93 AD2d 864 , mot for lv to app granted 60 NY2d 822 ).

21984–1984
People v. Barbour green
nyappdiv · 1983
2 sentences

1984We note that the persistent violent felony offender statutes (Penal Law, §§ 70.02, 70.04,70.08), as applied to defendant, do not violate the ex post facto clause of section 10 of article I of the United States Constitution (see People v Barbour, 96 AD2d 842 ; People v Balfour, 95 AD2d 812 ; People v Aiello, 93 AD2d 864 , mot for lv to app granted 60 NY2d 822 ).

1984HThis particular argument has been rejected by this court (People v Aiello, 93 AD2d 864 , app dsmd 61 NY2d 760 ; People v Covington, 96 AD2d 515 ; People v Barbour, 96 AD2d 842 ). 1i Nevertheless, the People concede, with commendable candor, that defendant’s adjudication as a second violent felony offender must be vacated, due to the fact that the crimes for which defendant presently stands convicted, i.e., attempted robbery in the second degree and criminal possession of a weapon in the third degree, were not violent felonies at the time of their commission, i.e., January 10,1979 and Jahuary

21984–1984
People v. Nival green
ny · 1974
2 sentences

1978In Beazell v Ohio ( 269 US 167, 170 ), which involved a statutory change making it more difficult for two persons jointly indicted to receive separate trials, the Supreme Court held that: "it is now well settled that statutory changes in the mode of trial or the rules of evidence, which do not deprive the accused of a defense and which operate only in a limited and unsubstantial manner to his disadvantage, are not prohibited.” In People v Nival ( 33 NY2d 391 ) the Court of Appeals held that application of CPL 60.25 to a crime committed prior to the effective date of that statute did not violat

1978(See Beazell v Ohio, 269 US 167 ; Thompson v Utah, 170 US 343 ; Kring v Missouri, 107 US 221 ; People v Conyers, 86 Misc 2d 754 ; People v Nival, 33 NY2d 391 ; People ex rel.

21978–1978
Lindsey v. Washington green
scotus · 1937
2 sentences

1976(Lindsey v Washington, 301 US 397 , where a change in the statute required imposition of statutory maximum term on all indeterminate sentences, where formerly court had discretion to set a term up to the maximum term allowed by statute, was held unconstitutional; cf. People v Adcock, 4 Misc 2d 758 .) In People v Warren ( 79 Misc 2d 777, 783 , remanded on other grounds for further proceedings 48 AD2d 859 ), the court, citing People v Oliver (supra), noted that "one’s punishment is not to be strictly equated with one’s sentence, but rather is to be considered in the broadest and most humane term

1939Horowitz v. Lawes, 168 Misc. 772 .) As said by the United States Supreme Court in Lindsey v. Washington ( 301 U. S. 397 ): “ The ex post facto clause looks to the standard of punishment prescribed by a statute, rather than to the sentence actually imposed.

21939–1976
People v. Sprint Nextel Corp. green
ny · 2015
1 sentence

2018ENTERED: AUGUST 30, 2018 DEPUTY CLERK Footnotes Footnote 1: In People v Sprint Nextel Corp. , the Court held that retroactive application of the NYFCA in a tax case was not barred by the ex post facto clause ( 26 NY3d at 113 ).

12018–2018
State v. Nelson green
nyappdiv · 2011
12014–2014
MATTER OF MILLER v. DeBuono green
ny · 1997
12014–2014
Forti v. New York State Ethics Commission green
ny · 1990
12014–2014
Calder v. Bull green
scotus · 1798
12013–2013
People v. Buss green
ny · 2008
12010–2010
Snuszki v. Wright green
nysupct · 2002
12004–2004
Snuszki v. Wright neutral
nyappdiv · 2003
12004–2004
M.G. v. Travis green
nyappdiv · 1997
12002–2002
Alejandro v. Goord green
nyappdiv · 2000
12002–2002
People v. Guszack green
nyappdiv · 1997
12001–2001
Kirk v. Hammock green
nyappdiv · 1986
12000–2000
Gonzalez v. Mann green
nyappdiv · 1992
12000–2000
People ex rel. Tyler v. Travis green
nyappdiv · 2000
12000–2000
People v. Friscia green
ny · 1980
12000–2000
People v. Brothers green
ny · 1980
12000–2000
Hong Ki Lee and Michael Chavis v. The Governor of the State of New York green
ca2 · 1996
11999–1999
Dixon v. Struna neutral
nyappdiv · 1997
11999–1999
People v. Shulman green
nycountyct · 1997
11997–1997
Rand v. Coughlin neutral
nyappdiv · 1996
11997–1997
State v. Erazo green
nj · 1991
11997–1997

Statutes the citing opinions construe

NY § N.Y. Correction Law § 168 (4) NY § N.Y. Correction Law § 855 (3) NY § N.Y. Penal Law § 220.00 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 372 (1958–2025) PA 355 (1950–2026) FL 245 (1982–2026) OH 219 (1993–2024) TX 166 (1971–2026) IL 135 (1974–2025) WA 112 (1989–2024) IN 107 (1974–2026) CT 91 (1981–2025) LA 70 (1978–2025) MO 61 (1988–2024) NY 61 (1939–2023) OR 60 (1980–2026) MS 58 (1976–2023) NJ 56 (1978–2026) TN 54 (1993–2025) KS 50 (1987–2026) MI 46 (1942–2026) SC 46 (1989–2023) AZ 43 (1976–2025) NC 42 (1980–2020) IA 40 (1979–2025) KY 29 (1983–2024) AR 29 (1987–2026) MA 29 (1980–2025) WV 27 (1980–2025) WI 27 (1994–2023) RI 26 (1917–2022) MD 25 (1980–2023) DE 23 (1985–2023) OK 23 (1980–2025) CO 22 (1990–2025) GA 22 (1972–2018) AL 21 (1981–2025) AK 21 (1986–2026) MT 20 (1979–2026) NE 17 (1983–2026) VT 17 (2008–2024) ID 17 (1979–2022) DC 17 (1972–2023) NV 16 (1977–2018) MN 15 (1985–2026) HI 15 (1994–2025) VA 14 (1984–2025) ME 14 (1984–2026) SD 11 (1993–2022) ND 10 (1980–2010) UT 10 (1983–2024) NM 9 (2004–2016) WY 7 (1895–2021) NH 6 (1974–2008) PR 4 (1949–1961)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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