People v. Hurst
Opinion of the Court
Defendant also failed to preserve for our review his contention that the evidence is legally insufficient to support the conviction with respect to the counts of falsifying business records in the first degree inasmuch as his motion for a trial order of dismissal was not “specifically directed” at the alleged error now asserted on appeal (People v Gray, 86 NY2d 10, 19 [1995] [internal quotation marks omitted]). In any event, that contention is without merit (see generally People v Bleakley, 69 NY2d 490, 495 [1987]). Defendant further contends that the evidence is legally insufficient to support the conviction with respect to the counts of grand larceny in the second and third degrees because he received the payments associated with those counts under a claim of right. We reject that contention. That defense applies where “the property was appropriated under a claim of right made in good faith” (Penal Law § 155.15 [1]). The People had the burden of disproving that defense beyond a reasonable doubt (see People v Zona, 14 NY3d 488, 492-493 [2010]; People v Chester, 50 NY2d 203, 210 [1980]), and we conclude that they met that burden here. Contrary to defendant’s further contention, viewing the evidence in light of the elements of the crimes of grand larceny in the second and third degrees as charged to the jury (see People v Danielson, 9 NY3d 342, 349 [2007]), we conclude that the verdict is not against the weight of the evidence (see generally Bleakley, 69 NY2d at 495).
Finally, we reject defendant’s contention that the court erred in failing to conduct a probing inquiry of a juror whom defense counsel reported to the court as appearing to be asleep during the jury charge. “[I]t is well established that [a] juror who has not heard all the evidence is grossly unqualified to render a verdict” (People v Jean-Philippe, 101 AD3d 1582, 1582 [2012] [internal quotation marks omitted]). Thus, a juror who has fallen asleep and missed part of the trial should be dismissed (see id. at 1582-1583). Here, defense counsel reported to the court that a juror “had [her] eyes closed and head over,” and he was “concerned that she didn’t hear all of the instructions.” The court, however, indicated that it had “watched her carefully, she did close her eyes, she was not sleeping.” Inasmuch as “the court had the benefit of its own observations, further inquiry was not required” (People v Lennon, 37 AD3d 853, 854 [2007], lv denied 9 NY3d 846 [2007]; see People v Booker, 49 AD3d 658, 660 [2008], lv denied 10 NY3d 859 [2008]; People v Phillips, 34 AD3d 1231, 1231 [2006], lv denied 8 NY3d 848 [2007]). Present — Scudder, P.J., Centra, Sconiers and Whalen, JJ.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.