People v. Sanders
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.