New York Court of Appeals
Individuals who, as indigent criminal defendants, were assigned public defenders in various criminal prosecutions brought putative class action against State, alleging that public defense system was deficient and presented unacceptable risk that indigent defendants were being denied constitutional right to counsel. The Supreme Court, Albany County, Eugene P. Devine, J., denied State’s motions to dismiss, and State appealed. The Supreme Court, Appellate Division, 66 A.D.3d 84, 883 N.Y.S.2d 349, reversed. Individuals appealed as of right.
Holdings: The Court of Appeals, Lippman, C.J., held that:
(1) individuals stated cognizable claim for constructive denial of their Sixth Amendment right to counsel, and
(2) arraignment was critical stage of criminal proceeding for purposes of right to counsel, even if guilty plea was not elicited at arraignment.