New York City DNA Database Subject to State Law, First Department Rules
The ruling will allow a man charged with illegally possessing a gun as a teenager to ask that his DNA be expunged from the local database, despite no specific state law governing such a request, the decision said.
May 29, 2019 at 06:10 PM
5 minute read
New York City's local DNA index that stores data on individuals accused of a crime is subject to state law that prescribes its ability to test, analyze and retain that information, a state appellate court in Manhattan decided this week.
The ruling will allow a man charged with illegally possessing a gun as a teenager to ask that his DNA be expunged from the local database, despite no specific state law governing such a request, the decision said.
It's the first time the Appellate Division, First Department considered the issue of whether state law applies to the local DNA databank, which is largely unregulated under statute. It was also the first time the panel addressed whether a trial court judge has the discretion to expunge a youthful offender's DNA profile from such a database.
The issue in the case was whether the defendant, identified as Samy F., could ask a trial court judge to have his DNA erased from the city's databank, which is operated by the Office of the Chief Medical Examiner.
The request isn't unusual; individuals acquitted on criminal charges can move to have their DNA removed from the city's databank.
The defendant had asked State Supreme Court Justice Ralph Fabrizio of the Bronx to have his DNA expunged from the OCME databank. But Fabrizio said he didn't have the legislative authority to grant such a request.
That's partly because the defendant's case was unlike others that seek to have their DNA expunged from such a database.
He was adjudicated as a youthful offender, rather than being tried as an adult. Youthful offenders in New York have their cases disposed without a conviction, and the decision is automatically sealed. The advantage to the classification is that youthful offenders don't have a criminal record; it's a different category to help younger individuals avoid that burden.
The defendant had consented to have his DNA taken as part of the criminal investigation that ultimately led to the charges against him. He had later moved to have that evidence suppressed in court, contesting whether he had agreed to the collection voluntarily or not.
But before the court decided on that motion, the defendant agreed to a youthful offender disposition. That essentially resolved the charges against him, but his DNA was still uploaded to the city's database at some point.
The defendant then filed to have his DNA and DNA-related records expunged from OCME's databank. Fabrizio said in his decision rejecting the defendant's request that state law didn't expressly govern the retention practices of the OCME databank, nor did it expressly provide for him to consider the expungement of DNA data lawfully collected from a youthful offender.
Associate Justice Judith Gische wrote in the decision from the Appellate Division, First Department that Fabrizio had the statutory authority to review the defendant's request.
“Clearly the Executive Law permits an adult who has voluntarily given his or her DNA in connection with a criminal investigation the right to seek discretionary expungement where a conviction had been reversed or vacated,” Gische wrote. “A youthful offender does not have and should not be afforded fewer pre-YO adjudication protections than an adult in the equivalent circumstances.”
Gische also wrote that, contrary to Fabrizio's decision, state law applied to the OCME database, despite it being a local DNA databank. That issue was in conflict because state law has left local DNA databases, like that kept by OCME, largely unregulated.
The defendant was represented by Terri Rosenblatt, the supervising attorney of the DNA unit at the Legal Aid Society, and Lenny Sandlar, an associate at Petrillo Klein & Boxer in Manhattan. The firm handled the case pro bono.
“The firm was pleased to take this case pro bono in partnership with the Legal Aid Society,” Sandlar said. “We welcome the Appellate Division ruling in our favor and look forward to continuing our pro bono work on behalf of indigent litigants.”
Rosenblatt urged state lawmakers in Albany to consider legislation that would set stricter regulations for local DNA databanks.
“The court's decision, which by nature could only resolve one nature's cases, still leaves unresolved important questions about OCME's unregulated, rogue DNA index,” Rosenblatt said. “The decision, while a success for our client, emphasizes the need for city and state lawmakers to make clear that the city cannot maintain its unregulated shadow database.”
Democrats have introduced a bill in recent weeks that would affirm a single, statewide DNA index and require that local databanks expunge their records. The bill hasn't moved from committee, but that's not unusual for new legislation.
If lawmakers seek to act on the measure, they'll have to do it quickly. They have the next three weeks to tie up any loose ends before they're scheduled to leave Albany for the year.
The state Attorney General's Office, which represented the trial court judge in the matter, declined to comment on the decision.
READ MORE:
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllRetired Judge Susan Cacace Elected Westchester DA in Win for Democrats
In Eric Adams Case and Other Corruption Matters, Prosecutors Seem Bent on Pushing Boundaries of Their Already Awesome Power
5 minute readEric Adams Trial Set for April as Defense Urges Dismissal of Bribery Count
Major Drug Companies Agree to Pay $49.1 Million to 50 States, Territories
3 minute readTrending Stories
- 1Read the Document: 'Google Must Divest Chrome', DOJ Says, Proposing Remedies in Search Monopoly Case
- 2Voir Dire Voyeur: I Find Out What Kind of Juror I’d Be
- 3When It Comes to Local Law 97 Compliance, You’ve Gotta Have (Good) Faith
- 4Legal Speak at General Counsel Conference East 2024: Virginia Griffith, Director of Business Development at OutsideGC
- 5Legal Speak at General Counsel Conference East 2024: Bill Tanenbaum, Partner & Chair, AI & Data Law Practice Group at Moses Singer
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250