People v. Cohen
Opinion of the Court
Appeal from a judgment of Erie County Court (McCarthy, J.), entered March 21, 2000, convicting defendant after a jury trial of, inter alia, burglary in the second degree.
It is hereby ordered that the case is held, the decision is reserved and the matter is remitted to Erie County Court for further proceedings in accordance with the following memoran
We are unable to discern from this record whether defendant was present at sidebar conferences during jury selection and thus are unable to determine whether defendant’s right to be present at a material stage of the trial was violated. “[A] sidebar interview that concerns a juror’s background, bias or hostility, or ability to weigh the evidence objectively is a material stage of trial at which a defendant has a right to be present * * *, and a waiver by defendant [of that right] will not be inferred from a silent record” (People v Lucious, 269 AD2d 766, 767). In addition, because at least two prospective jurors were excused by stipulation of the parties, any failure to include defendant in sidebar conferences concerning those prospective jurors would not be harmless error (see id. at 768). We therefore hold the case, reserve decision and remit the matter to Erie County Court for a reconstruction hearing on this issue (see id. at 769). Present — Green, J.P., Wisner, Scudder, Burns and Hayes, JJ.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.