People v. Hall
Opinion of the Court
—Judgment unanimously affirmed. Memorandum: Defendant contends that Supreme Court erred in failing to give proper limiting instructions regarding evidence of prior uncharged crimes. Although evidence of uncharged crimes is generally not admissible (see, People v Beam, 57 NY2d 241, 250), it may be received if it helps to establish some element of the crime under consideration, or is relevant because of some recognized exception to the general rule (People v Alvino, 71 NY2d 233, 241-242). Here, evidence of an uncharged crime was introduced on the direct examination by defendant of his expert witness and formed the basis for the expert’s opinion concerning defendant’s ability to form the intent to commit the crimes charged. Defendant contends that he was prejudiced by the court’s failure to give limiting instructions. Defendant, however, failed to request a limiting instruction when the evidence was offered, nor did he object to the prosecution experts’ use of the same information. Defendant requested a limiting instruction for the first time at the charge conference. Although the better course may have been to grant the request, any error was harmless considering the overwhelming evidence of guilt (see, People v Crimmins, 36 NY2d 230, 242).
Defendant also contends that the proof is legally insufficient
Case-law data current through December 31, 2025. Source: CourtListener bulk data.