People v. Sanders
Cases that cite this one
5 later published cases cite this decision.
- People v. Boyer (N.Y. 2013)
- People v. Snipes (Appellate Division of the Supreme Court of New York 2013)
- People v. Snipes (Appellate Division of the Supreme Court of New York 2013)
- People v. Snipes (Appellate Division of the Supreme Court of New York 2012)
- People v. Snipes (Appellate Division of the Supreme Court of New York 2012)
This list shows which later cases cite this one. It does not say how they treated it, and no review of that has been done. Not a substitute for Shepard’s or KeyCite — verify before relying.
Opinion of the Court
The court properly adjudicated defendant a second violent felony offender rather than a persistent violent felony offender.
Gonzalez, EJ., and Sweeny, J., concur in a separate memorandum by Sweeny, J., as follows: I am constrained by this Court’s decision in People v Butler (88 AD3d 470 [1st Dept 2011], lv denied 18 NY3d 992 [2012]) to affirm. I write separately to voice my concern that this issue is not fully resolved. Butler is at odds with the Second Department case of People v Naughton (93 AD3d 809 [2d Dept 2012], lv denied 19 NY3d 865 [2012]). Naughton clearly holds, contrary to Butler, that it is irrelevant whether the defendant or the government brought the application for a resentence under People v Sparber (10 NY3d 457 [2008]) and that the original sentence date is always determinative as the predicate for persistent violent felony offender status.
It is apparent from these differing opinions that the decision in People v Acevedo (17 NY3d 297 [2011]) to which both Butler and Naughton refer, did not clarify this question. We look to the Court of Appeals for guidance on this crucial sentencing issue.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.