People v. Morrison
Opinion of the Court
Memorandum: Defendant appeals from a judgment convicting him upon a jury verdict of assault in the second degree (Penal Law § 120.05 [4]) and upon his plea of guilty of reckless endangerment in the second degree (§ 120.20). The conviction arises out of an incident in which defendant, while a passenger in the front seat of a vehicle, interfered with the driver’s operation of the vehicle and caused it to collide with the victim’s vehicle. The contention of defendant that County Court erred in conducting the Sandoval hearing in his absence is raised for the first time in defendant’s reply brief and thus is not properly before us (see People v Sponburgh, 61 AD3d 1415 [2009], lv denied 12 NY3d 929 [2009]; People v Donahue, 21 AD3d 1359 [2005], lv denied 6 NY3d 775 [2006]; People v McQueen, 11 AD3d 1005, 1006 [2004], lv denied 4 NY3d 765 [2005]). Nevertheless, we exercise our power to review it as a matter of discretion in the interest of justice, and we agree with defendant that his presence at the Sandoval hearing was required (see People v Favor, 82 NY2d 254, 258 [1993]; see generally People v Dokes, 79 NY2d 656, 660-662 [1992]). The court’s Sandoval ruling was
Viewing the evidence in light of the elements of the crime of assault in the second degree as charged to the jury (see People v Danielson, 9 NY3d 342, 349 [1961]), we reject defendant’s contention that the verdict is against the weight of the evidence (see generally People v Bleakley, 69 NY2d 490, 495 [1987]). “Giving ‘appropriate deference to the jury’s superior opportunity to assess the witnesses’ credibility’ ” (People v Marshall, 65 AD3d 710, 712 [2009]), we conclude that, although a different result would not have been unreasonable, the jury was entitled to credit the victim’s version of how the accident occurred over defendant’s version (see People v Wedlington, 67 AD3d 1472 [2009]).
In view of our determination that reversal of the judgment is required, we need not review defendant’s remaining contentions. Nevertheless, because we are granting a new trial, we note in the interest of judicial economy that the testimony of the witnesses at trial concerning the statements of the driver of the vehicle in which defendant was a passenger with respect to the cause of the accident constituted inadmissible hearsay (see generally People v Huertas, 75 NY2d 487, 491-492 [1990]). That testimony also impermissibly bolstered the credibility of the driver at trial, particularly with respect to her testimony concerning the cause of the accident (see generally People v Davis, 67 AD3d 1397 [2009]; People v Osborne, 63 AD3d 1707
Case-law data current through December 31, 2025. Source: CourtListener bulk data.