People v. Townsend
Opinion of the Court
—Appeal by the defendant from a judgment of the Supreme Court, Queens
Ordered that the judgment is affirmed.
Contrary to the defendant’s contention, the trial court did not conduct a Sandoval hearing (see People v Sandoval, 34 NY2d 371) in his absence, thereby depriving him of his right to be present at all material stages of his trial. During a conference conducted in chambers, the court merely adopted a prior Sandoval ruling; it did not conduct a hearing or consider the Sandoval application de novo (cf. People v Dokes, 79 NY2d 656; People v Geddes, 207 AD2d 987). Since there was no potential for additional meaningful input by the defendant, his presence would have been wholly superfluous (see People v Favor, 82 NY2d 254, 268; People v McMoore, 214 AD2d 893, 894). Santucci, J.P., Altman, S. Miller and McGinity, JJ., concur.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.