People v. Brois

2023 NY Slip Op 34739(U)
CourtNew York Supreme Court, Westchester County
DecidedSeptember 13, 2023
DocketIndictment No. 23-71141-02
StatusUnpublished

This text of 2023 NY Slip Op 34739(U) (People v. Brois) is published on Counsel Stack Legal Research, covering New York Supreme Court, Westchester County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Brois, 2023 NY Slip Op 34739(U) (N.Y. Super. Ct. 2023).

Opinion

People v Brois 2023 NY Slip Op 34739(U) September 13, 2023 Supreme Court, Westchester County Docket Number: Indictment No. 23-71141-02 Judge: Anne E. Minihan Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. FILED

AND ENTERED

~:: :p~:::H;;::~~-~E;-vax1rEo~ SUPREME COURT: STATE OF NEW YORK ON ~r /3 ~ 2023 WESTCHESTER

COUNTY CLERK -against- SEP 15 2023 BRANDON BRO IS ,, . rg~it'R %Lf~k'' DECISION & ORDER . . . D'~AftTa'6P.F WESTCHESTERindictment No. 23-71141-02 -----------------------------. ------------------------------------X MINIHAN, J.

Defendant, Brandon Brois, is charged by Westchester County Indictment Number 23- 71141-02 with Criminal Possession of a Weapon in the Second Degree (Penal Law§ 265.03[3]), Criminal Possession of a Weapon in the Third Degree (Penal Law§ 265.02[1]), and Criminal Possession of a Weapon in the Fourth Degree (Penal Law§ 265.01 [4]) (9 counts). Defendant is charged. together with his parents, codefendants Theodore Brois and Helene Brois, with Criminal · Possession of a Weapon in the Second Degree (Penal Law§ 265.03[2]), Criminal Possession of a Weapon in the Second Degree (Penal Law§ 265.03[3]) (2 counts), Criminal Possession of a Weapon in the Third Degree (Penal Law§ 265.02[2]), and Criminal Possession of a Weapon in the Third Degree (Penal Law§ 265.02[7]) (2 counts).

Defendant has filed an omnibus motion consisting of a Notice of Motion, an Affirmation in Support, and a Memorandum of Law. In response, the People filed an Affirmation in Opposition and a Memorandum of Law. On August 15, 2023, defendant filed a Reply.

I. MOTION to DISMISS on CONSTITUTIONAL GROUNDS

Defendant moves to dismiss the jndictment against him on the ground that the Second Amendment, as interpreted by New York State Rifle & Pistol Association, Inc. v Bruen, 142 S.Ct. 2111 (2022), gives him a constitutional right to possess firearms in his home without a license.

Defe.ndant argues that New York's criminalization of firearms in one's home "infringes on the ancient right to keep and bear arms recognized in the Second Amendment to the United States Constitution" (see Helene Brois's Memorandum of Law, p 1) 1 and asserts that "the prosecution ... cannot continue as it offends hundreds of years of well-settled law which permits, as here, possession of weapons _in one's home for the purpose of self-protection" (see Helene Brois's Affirmation, p 2).

Defendant further argues that "Bruen instructs courts to under-take a comprehensive review of history to determine if Second Amendment restrictions are 'consistent with the Nation's historical tradition of firearm regulation"' (see Helene Brois's Memorandum of Law, p

1 Defendant has fully adopted the arguments made in codefendant Helen Brois's motion papers with respect to this

motion.

[* 1] 9, citing Bruen, 142 S.Ct. at 2130). Applying the Bruen instruction, defendant asks this Court to find New York's Penal Law statutes criminalizing unregistered firearms in one's home unconstitutional under the Second Amendment. 2

Defendant acknowledges that his previous conviction for Attempted Criminal Possession of a Weapon in the Second Degree places him in a different position than his mother, codefendant Helene Brois, to make the arguments supra. However, defendant argues that "there has been no controlling, dispositive caselaw which stands for the proposition that a conviction for a prior possession of a weapon ... alone provides a sufficient historical analogue of prohibition as to strip any and all such offenders from Second Amendment protection" (see Defendant's Affirmation, p 2). As such, defendant maintains the Second Amendment constitutional right extends even to his possession of firearms despite his prior felony conviction.

In Bruen, the Supreme Court ruled that the Second Amendment protects the right to carry a weapon in public for self-defense, which may not be conditioned on "demonstrating to government officers some special need" to do so (Bruen, 142 S.Ct. at 2156). Thus, the Court held that "New York's proper-cause requirement violate[d] the Fourteenth Amendment [since] it prevent[ed] law-abiding citizens with ordinary self-defense needs from exercising their right to keep and bear arms" (Bruen, 142 S.Ct. at 2156). Significantly, the Court did not disturb any other aspect of New York's firearm licensing scheme. The Supreme Court made clear that individuals with prior felony convictions or a history of mental illness, among other examples, may be denied the right to possess a gun. Justice Alito, concurring in Bruen, indicated that states may impose restrictions on the possession or carrying of guns and added that the Bruen holding "decides nothing about who may lawfully possess a firearm or the requirements that must be met to buy a gun [n]or does it decide anything about the kinds of weapons that people may possess" (Bruen, 142 S.Ct at 2157 [Alito, J., concurring]). The Supreme Court merely held that a law- abiding citizen applying for a concealed carry permit cannot be required to show "proper cause" - that is, an "atypical need for armed self-defense" (Bruen, 142 S.Ct. at 2138, fn 9). Thus, there is no constitutional impediment that restricts a state's ability to continue to require that a person obtain a license to purchase or possess a firearm or require that a person obtain a concealed carry permit in order to carry a handgun in public.

Bruen does not convey to citizens an unfettered right to possess weapons in their homes nor did it invalidate New York's laws criminalizing the unlicensed possession of firearms. The Bruen decision does not impact the constitutionality of the statutes criminalizing possession of a firearm because states maintain the right under the United States Constitution to require gun licenses for lawful possession and may instill certain requirements as part of the application process, such as undergoing a background check or passing a firearms safety course (Bruen, 142 S.Ct. at 2138, fn 9). Neither does the Second Amendment or Bruen confer an unqualified entitlement to possess a deadly weapon in one's home without restriction. "The right [secured by the Second Amendment is] not a right to k~ep and carry any weapon whatsoever in any manner whatsoever and for whatever purpose" (Bruen, 142 S.Ct. at 2128 [citations and internal quotation marks omitted]). In fact, the Supreme Court acknowledged New York's requirement that "[a] license applicant who wants to possess a firearm at home ... must convince a licensing

2 The New York Attorney General's Office, in a letter dated September 5, 2023, has indicated it will not intervene in this challenge. 2

[* 2] officer ... that, among other things, he is of good moral character, has no history of crime or mental illness, and that no good cause exists for the denial of the license" and did not find anything improper with those requirements (Bruen, 142 S.Ct. at 2122-23 [citations and internal quotation marks omitted]). Since Bruen was decided, no trial court has interpreted Bruen as prohibiting, on constitutional grounds, the criminal prosecution of a defendant for the unlicensed possession of a firearm under the Penal Law. In fact, in June of this year, the Appellate Division, Second Department, held that "[t]he ruling in Bruen ha[s] no impact on the constitutionality of New York State's criminal possession of a weapon statutes" (People v Manners, 217 AD3d 683, 686 [2023]).

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Bluebook (online)
2023 NY Slip Op 34739(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-brois-nysupctwster-2023.