presence defense (New York) · Go Syfert
← New York issues

presence defense in New York

126 New York opinions name it 7 courts 1858–2026 7 in the last five years

The cases below were cited by New York courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (40)

CaseFollowedCited
Indian Harbor Ins. v. Clifford Zuckergreen
ca6 · 2017 · cited in 3 New York opinions naming this issue, 2020–2020
2 sentences

2020Co. v Zucker , 860 F3d 373, 375 [6th Cir 2017]; Biltmore Assoc.

2020Co. v Zucker , 860 F3d 373, 375 [6th Cir 2017]; Biltmore Assoc.

33
People v. Guerrerogreen
ny · 2009 · cited in 3 New York opinions naming this issue, 2013–2014
2 sentences

2014As the People correctly concede, the Supreme Court failed to pronounce sentence on the conviction of assault in the third degree in the defendant’s presence in violation of its obligation under CPL 380.20 (see People v Guerrero, 12 NY3d 45, 47 [2009]; People v Sparber, 10 NY3d 457, 472 [2008]; People v Hernandez, 107 AD3d 1016, 1016-1017 [2013]).

2013The People correctly concede that the County Court failed to pronounce sentence in the defendant’s presence in violation of its obligation under CPL 380.20 (see People v Guerrero, 12 NY3d 45, 47 [2009]; People v Sparber, 10 NY3d 457, 472 [2008]).

33
People v. Sparbergreen
ny · 2008 · cited in 3 New York opinions naming this issue, 2013–2014
2 sentences

2014As the People correctly concede, the Supreme Court failed to pronounce sentence on the conviction of assault in the third degree in the defendant’s presence in violation of its obligation under CPL 380.20 (see People v Guerrero, 12 NY3d 45, 47 [2009]; People v Sparber, 10 NY3d 457, 472 [2008]; People v Hernandez, 107 AD3d 1016, 1016-1017 [2013]).

2013The People correctly concede that the County Court failed to pronounce sentence in the defendant’s presence in violation of its obligation under CPL 380.20 (see People v Guerrero, 12 NY3d 45, 47 [2009]; People v Sparber, 10 NY3d 457, 472 [2008]).

33
People v. Simmonsgreen
nyappdiv · 2012 · cited in 3 New York opinions naming this issue, 2016–2016
2 sentences

2016Consequently, we conclude that the court did not violate its core O’Rama responsibilities (see People v Barnes, 139 AD3d 1371, 1372 [2016], lv denied 28 NY3d 926 [2016]) and, therefore, preservation was required (see People v Brito, 135 AD3d 627, 628-629 [2016], lv denied 27 NY3d 1066 [2016]; People v Simmons, 97 AD3d 842, 843 [2012], lv denied 20 NY3d 935 [2012]; People v Peller, 8 AD3d 1123, 1123-1124 [2004], lv denied 3 NY3d 679 [2004]).

2016Consequently, we conclude that the court did not violate its core O’Rama responsibilities (see People v Barnes, 139 AD3d 1371, 1372 [2016], lv denied 28 NY3d 926 [2016]) and, therefore, preservation was required (see People v Brito, 135 AD3d 627, 628-629 [2016], lv denied 27 NY3d 1066 [2016]; People v Simmons, 97 AD3d 842, 843 [2012], lv denied 20 NY3d 935 [2012]; People v Peller, 8 AD3d 1123, 1123-1124 [2004], lv denied 3 NY3d 679 [2004]).

23
People v. Britogreen
nyappdiv · 2016 · cited in 3 New York opinions naming this issue, 2016–2016
2 sentences

2016Consequently, we conclude that the court did not violate its core O’Rama responsibilities (see People v Barnes, 139 AD3d 1371, 1372 [2016], lv denied 28 NY3d 926 [2016]) and, therefore, preservation was required (see People v Brito, 135 AD3d 627, 628-629 [2016], lv denied 27 NY3d 1066 [2016]; People v Simmons, 97 AD3d 842, 843 [2012], lv denied 20 NY3d 935 [2012]; People v Peller, 8 AD3d 1123, 1123-1124 [2004], lv denied 3 NY3d 679 [2004]).

2016Consequently, we conclude that the court did not violate its core O’Rama responsibilities (see People v Barnes, 139 AD3d 1371, 1372 [2016], lv denied 28 NY3d 926 [2016]) and, therefore, preservation was required (see People v Brito, 135 AD3d 627, 628-629 [2016], lv denied 27 NY3d 1066 [2016]; People v Simmons, 97 AD3d 842, 843 [2012], lv denied 20 NY3d 935 [2012]; People v Peller, 8 AD3d 1123, 1123-1124 [2004], lv denied 3 NY3d 679 [2004]).

23
People v. Pellergreen
nyappdiv · 2004 · cited in 3 New York opinions naming this issue, 2016–2016
2 sentences

2016Consequently, we conclude that the court did not violate its core O’Rama responsibilities (see People v Barnes, 139 AD3d 1371, 1372 [2016], lv denied 28 NY3d 926 [2016]) and, therefore, preservation was required (see People v Brito, 135 AD3d 627, 628-629 [2016], lv denied 27 NY3d 1066 [2016]; People v Simmons, 97 AD3d 842, 843 [2012], lv denied 20 NY3d 935 [2012]; People v Peller, 8 AD3d 1123, 1123-1124 [2004], lv denied 3 NY3d 679 [2004]).

2016Consequently, we conclude that the court did not violate its core O’Rama responsibilities (see People v Barnes, 139 AD3d 1371, 1372 [2016], lv denied 28 NY3d 926 [2016]) and, therefore, preservation was required (see People v Brito, 135 AD3d 627, 628-629 [2016], lv denied 27 NY3d 1066 [2016]; People v Simmons, 97 AD3d 842, 843 [2012], lv denied 20 NY3d 935 [2012]; People v Peller, 8 AD3d 1123, 1123-1124 [2004], lv denied 3 NY3d 679 [2004]).

23
People v. Barnesgreen
nyappdiv · 2016 · cited in 3 New York opinions naming this issue, 2016–2016
2 sentences

2016Consequently, we conclude that the court did not violate its core O’Rama responsibilities (see People v Barnes, 139 AD3d 1371, 1372 [2016], lv denied 28 NY3d 926 [2016]) and, therefore, preservation was required (see People v Brito, 135 AD3d 627, 628-629 [2016], lv denied 27 NY3d 1066 [2016]; People v Simmons, 97 AD3d 842, 843 [2012], lv denied 20 NY3d 935 [2012]; People v Peller, 8 AD3d 1123, 1123-1124 [2004], lv denied 3 NY3d 679 [2004]).

2016Consequently, we conclude that the court did not violate its core O’Rama responsibilities (see People v Barnes, 139 AD3d 1371, 1372 [2016], lv denied 28 NY3d 926 [2016]) and, therefore, preservation was required (see People v Brito, 135 AD3d 627, 628-629 [2016], lv denied 27 NY3d 1066 [2016]; People v Simmons, 97 AD3d 842, 843 [2012], lv denied 20 NY3d 935 [2012]; People v Peller, 8 AD3d 1123, 1123-1124 [2004], lv denied 3 NY3d 679 [2004]).

23
People v. Bufordgreen
ny · 1987 · cited in 3 New York opinions naming this issue, 1989–1997
2 sentences

1997The court questioned the two jurors involved separately, in camera, in the presence of defense counsel and the prosecutor, and stated the reason for its ruling on the record (People v Buford, 69 NY2d 290 ).

1989Second, while it was improper for the court to conduct the interview with the juror outside the presence of defense counsel and the defendant (see, People v Buford, supra, at 299), reversal is not warranted since the defendant effectively consented to this procedure and no prejudice has been demonstrated.

23
People v. Asarogreen
ny · 2013 · cited in 2 New York opinions naming this issue, 2022–2022
2 sentences

2022Indeed, it was sufficient that defendant drove at a speed significantly faster than the speed limit [FN4] and committed the "additional affirmative act" of driving through a red light while another car, with headlights illuminated and possibly strobe lights as well, was passing through the intersection, and never even braking before the collision ( People v Asaro , 21 NY3d 677, 684 [2013][internal quotation [*9]marks omitted]).

2022Indeed, it was sufficient that defendant drove at a speed significantly faster than the speed limit [FN4] and committed the "additional affirmative act" of driving through a red light while another car, with headlights illuminated and possibly strobe lights as well, was passing through the intersection, and never even braking before the collision ( People v Asaro , 21 NY3d 677, 684 [2013][internal quotation [*9]marks omitted]).

22
People v. Rodriguezgreen
nyappdiv · 2016 · cited in 2 New York opinions naming this issue, 2016–2016
2 sentences

2016Here, we conclude that County Court properly determined that the caseworker obtained the statements and letters in violation of defendant’s right to counsel (see generally People v Lopez, 16 NY3d 375, 380 [2011]), inasmuch as there was such a degree of investigatory cooperation between the caseworker and a Village of Penn Yan police investigator that the caseworker acted as the agent of the police in questioning defendant and obtaining the letters from him outside the presence of defense counsel (see People v Wilhelm, 34 AD3d 40, 46-50 [2006]; People v Greene, 306 AD2d 639, 640-641 [2003], lv

2016Here, we conclude that County Court properly determined that the caseworker obtained the statements and letters in violation of defendant’s right to counsel (see generally People v Lopez, 16 NY3d 375, 380 [2011]), inasmuch as there was such a degree of investigatory cooperation between the caseworker and a Village of Penn Yan police investigator that the caseworker acted as the agent of the police in questioning defendant and obtaining the letters from him outside the presence of defense counsel (see People v Wilhelm, 34 AD3d 40, 46-50 [2006]; People v Greene, 306 AD2d 639, 640-641 [2003], lv

22
People v. Wilhelmgreen
nyappdiv · 2006 · cited in 2 New York opinions naming this issue, 2016–2016
2 sentences

2016Here, we conclude that County Court properly determined that the caseworker obtained the statements and letters in violation of defendant’s right to counsel (see generally People v Lopez, 16 NY3d 375, 380 [2011]), inasmuch as there was such a degree of investigatory cooperation between the caseworker and a Village of Penn Yan police investigator that the caseworker acted as the agent of the police in questioning defendant and obtaining the letters from him outside the presence of defense counsel (see People v Wilhelm, 34 AD3d 40, 46-50 [2006]; People v Greene, 306 AD2d 639, 640-641 [2003], lv

2016Here, we conclude that County Court properly determined that the caseworker obtained the statements and letters in violation of defendant’s right to counsel (see generally People v Lopez, 16 NY3d 375, 380 [2011]), inasmuch as there was such a degree of investigatory cooperation between the caseworker and a Village of Penn Yan police investigator that the caseworker acted as the agent of the police in questioning defendant and obtaining the letters from him outside the presence of defense counsel (see People v Wilhelm, 34 AD3d 40, 46-50 [2006]; People v Greene, 306 AD2d 639, 640-641 [2003], lv

22
People v. Lopezgreen
ny · 2011 · cited in 2 New York opinions naming this issue, 2016–2016
2 sentences

2016Here, we conclude that County Court properly determined that the caseworker obtained the statements and letters in violation of defendant’s right to counsel (see generally People v Lopez, 16 NY3d 375, 380 [2011]), inasmuch as there was such a degree of investigatory cooperation between the caseworker and a Village of Penn Yan police investigator that the caseworker acted as the agent of the police in questioning defendant and obtaining the letters from him outside the presence of defense counsel (see People v Wilhelm, 34 AD3d 40, 46-50 [2006]; People v Greene, 306 AD2d 639, 640-641 [2003], lv

2016Here, we conclude that County Court properly determined that the caseworker obtained the statements and letters in violation of defendant’s right to counsel (see generally People v Lopez, 16 NY3d 375, 380 [2011]), inasmuch as there was such a degree of investigatory cooperation between the caseworker and a Village of Penn Yan police investigator that the caseworker acted as the agent of the police in questioning defendant and obtaining the letters from him outside the presence of defense counsel (see People v Wilhelm, 34 AD3d 40, 46-50 [2006]; People v Greene, 306 AD2d 639, 640-641 [2003], lv

22
People v. Ramtahalgreen
ny · 2016 · cited in 2 New York opinions naming this issue, 2016–2016
2 sentences

2016Here, we conclude that County Court properly determined that the caseworker obtained the statements and letters in violation of defendant’s right to counsel (see generally People v Lopez, 16 NY3d 375, 380 [2011]), inasmuch as there was such a degree of investigatory cooperation between the caseworker and a Village of Penn Yan police investigator that the caseworker acted as the agent of the police in questioning defendant and obtaining the letters from him outside the presence of defense counsel (see People v Wilhelm, 34 AD3d 40, 46-50 [2006]; People v Greene, 306 AD2d 639, 640-641 [2003], lv

2016Here, we conclude that County Court properly determined that the caseworker obtained the statements and letters in violation of defendant’s right to counsel (see generally People v Lopez, 16 NY3d 375, 380 [2011]), inasmuch as there was such a degree of investigatory cooperation between the caseworker and a Village of Penn Yan police investigator that the caseworker acted as the agent of the police in questioning defendant and obtaining the letters from him outside the presence of defense counsel (see People v Wilhelm, 34 AD3d 40, 46-50 [2006]; People v Greene, 306 AD2d 639, 640-641 [2003], lv

22
People v. Greenegreen
nyappdiv · 2003 · cited in 2 New York opinions naming this issue, 2016–2016
2 sentences

2016Here, we conclude that County Court properly determined that the caseworker obtained the statements and letters in violation of defendant’s right to counsel (see generally People v Lopez, 16 NY3d 375, 380 [2011]), inasmuch as there was such a degree of investigatory cooperation between the caseworker and a Village of Penn Yan police investigator that the caseworker acted as the agent of the police in questioning defendant and obtaining the letters from him outside the presence of defense counsel (see People v Wilhelm, 34 AD3d 40, 46-50 [2006]; People v Greene, 306 AD2d 639, 640-641 [2003], lv

2016Here, we conclude that County Court properly determined that the caseworker obtained the statements and letters in violation of defendant’s right to counsel (see generally People v Lopez, 16 NY3d 375, 380 [2011]), inasmuch as there was such a degree of investigatory cooperation between the caseworker and a Village of Penn Yan police investigator that the caseworker acted as the agent of the police in questioning defendant and obtaining the letters from him outside the presence of defense counsel (see People v Wilhelm, 34 AD3d 40, 46-50 [2006]; People v Greene, 306 AD2d 639, 640-641 [2003], lv

22
People v. Castillogreen
ny · 1992 · cited in 2 New York opinions naming this issue, 2015–2015
2 sentences

2015In People v Castillo, an informant's fear justified the court's ex parte proceeding to determine whether to disclose the informer's identity or statements ( 80 NY2d 578, 586 [1992], cert denied 507 US 1033 [1993]).

2015In People v Castillo, an informant’s fear justified the court’s ex parte proceeding to determine whether to disclose the informer’s identity or statements ( 80 NY2d 578, 586 [1992], cert denied 507 US 1033 [1993]).

22
People v. Henrygreen
nyappdiv · 2011 · cited in 2 New York opinions naming this issue, 2013–2013
2 sentences

2013Accordingly, the sentence must be vacated and the matter remitted to the County Court, Westchester County, for resentencing on the conviction of robbery in the first degree in accordance with CPL 380.20 (see People v McGhee, 96 AD3d 786 [2012]; People v Henry, 80 AD3d 625, 626 [2011]).

2013Accordingly, the sentence must be vacated and the matter remitted to the County Court, Westchester County, for resentencing on the conviction of robbery in the first degree in accordance with CPL 380.20 (see People v McGhee, 96 AD3d 786 [2012]; People v Henry, 80 AD3d 625, 626 [2011]).

22
Calvaruso v. Hunter Ambulette-Ambulance, Inc.green
nyappdiv · 2011 · cited in 2 New York opinions naming this issue, 2013–2013
2 sentences

2013In light of the mother’s presence at the hearing on October 24, 2011, when her attorney cross-examined the petitioner Alice T., the mother’s actual knowledge of the date and time of the continued hearing, which is undisputed, and her failure to contact her attorney to advise him regarding her failure to appear on the final date of the hearing, the Family Court did not improvidently exercise its discretion in denying the mother’s attorney’s request for an adjournment (cf. Matter of O’Leary v Frangomihalos, 89 AD3d at 949 ; Matter of Kinara C. [Jerome C.], 89 AD3d at 841; Matter of Nicholas S.,

2013In light of the mother’s presence at the hearing on October 24, 2011, when her attorney cross-examined the petitioner Alice T., the mother’s actual knowledge of the date and time of the continued hearing, which is undisputed, and her failure to contact her attorney to advise him regarding her failure to appear on the final date of the hearing, the Family Court did not improvidently exercise its discretion in denying the mother’s attorney’s request for an adjournment (cf. Matter of O’Leary v Frangomihalos, 89 AD3d at 949 ; Matter of Kinara C. [Jerome C.], 89 AD3d at 841; Matter of Nicholas S.,

22
People v. Darbygreen
ny · 1990 · cited in 6 New York opinions naming this issue, 1991–2001
2 sentences

2001The presence of defense counsel at the inquiries was sufficient to afford defendants a “fair and just hearing” (People v Mullen, supra, at 6; cf., People v Darby, 75 NY2d 449 , supra), and defendants were present when their attorneys unsuccessfully argued for a mistrial and to disqualify the two jurors.

1993Because a juror, whom defendant had accepted and who had been sworn, was discharged by the court outside the presence of defense counsel, defendant was denied the minimum safeguard necessary to afford him a " 'fair and just hearing’ ” (People v Mullen, supra, at 5, quoting Snyder v Massachusetts, 291 US 97, 108 ; see also, People v Darby, supra, at 453).

16
The People v.Kenneth Nealongreen
ny · 2015 · cited in 1 New York opinions naming this issue, 2025–2025
11
Matter of Banks (Gwendolyn R.)green
nyappdiv · 2016 · cited in 1 New York opinions naming this issue, 2025–2025
11
People v. Pittmangreen
nyappdiv · 2013 · cited in 1 New York opinions naming this issue, 2024–2024
11
People v. Harrisgreen
ny · 1982 · cited in 1 New York opinions naming this issue, 2021–2021
11
People v. Rahmangreen
nyappdiv · 2016 · cited in 1 New York opinions naming this issue, 2020–2020
11
Scherer v. Golub Corp.green
nyappdiv · 2012 · cited in 1 New York opinions naming this issue, 2018–2018
11
Rose Park Place, Inc. v. Stategreen
nyappdiv · 2014 · cited in 1 New York opinions naming this issue, 2018–2018
11
The People v. William Middlebrooks / The People v. Fabrice Lowegreen
ny · 2015 · cited in 1 New York opinions naming this issue, 2018–2018
11
People v. Narayangreen
ny · 1981 · cited in 1 New York opinions naming this issue, 2015–2015
11
People v. Graygreen
ny · 1995 · cited in 1 New York opinions naming this issue, 2015–2015
11
People v. Hernandezgreen
nyappdiv · 2013 · cited in 1 New York opinions naming this issue, 2014–2014
11
People v. Woodrowgreen
nyappdiv · 2011 · cited in 1 New York opinions naming this issue, 2012–2012
11
In re Edward G.N.green
nyappdiv · 2005 · cited in 1 New York opinions naming this issue, 2009–2009
11
Piacquadio v. Recine Realty Corp.green
ny · 1994 · cited in 1 New York opinions naming this issue, 2006–2006
11
Farrago v. Great Atlantic & Pacific Tea Co.green
nyappdiv · 2005 · cited in 1 New York opinions naming this issue, 2006–2006
11
People v. Bonapartegreen
ny · 1991 · cited in 1 New York opinions naming this issue, 2005–2005
11
People v. Hameedgreen
ny · 1996 · cited in 1 New York opinions naming this issue, 2005–2005
11
Houston v. Stategreen
alaska · 1979 · cited in 1 New York opinions naming this issue, 2005–2005
11
People v. Keengreen
ny · 2000 · cited in 1 New York opinions naming this issue, 2003–2003
11
People v. Robertsongreen
nyappdiv · 1995 · cited in 1 New York opinions naming this issue, 2003–2003
11
People v. Harrisgreen
ny · 2002 · cited in 1 New York opinions naming this issue, 2003–2003
11
People v. Reyesgreen
nyappdiv · 2001 · cited in 1 New York opinions naming this issue, 2003–2003
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in New York. Read the followed side critically anyway.

Also cited on this issue (40)

CaseCitedYears
Snyder v. Massachusetts green
scotus · 1934
2 sentences

1993Because a juror, whom defendant had accepted and who had been sworn, was discharged by the court outside the presence of defense counsel, defendant was denied the minimum safeguard necessary to afford him a " 'fair and just hearing’ ” (People v Mullen, supra, at 5, quoting Snyder v Massachusetts, 291 US 97, 108 ; see also, People v Darby, supra, at 453).

1992Indeed, it cannot be stated in this case that the defendant’s presence at the inquiry would have borne any relation to his ability to defend against the charges (see, Snyder v Massachusetts, 291 US 97 ; People v Bumbury, 186 AD2d 671 ).

41990–1993
People v. Peckham green
ny · 2004
2 sentences

2016Consequently, we conclude that the court did not violate its core O’Rama responsibilities (see People v Barnes, 139 AD3d 1371, 1372 [2016], lv denied 28 NY3d 926 [2016]) and, therefore, preservation was required (see People v Brito, 135 AD3d 627, 628-629 [2016], lv denied 27 NY3d 1066 [2016]; People v Simmons, 97 AD3d 842, 843 [2012], lv denied 20 NY3d 935 [2012]; People v Peller, 8 AD3d 1123, 1123-1124 [2004], lv denied 3 NY3d 679 [2004]).

2016Consequently, we conclude that the court did not violate its core O’Rama responsibilities (see People v Barnes, 139 AD3d 1371, 1372 [2016], lv denied 28 NY3d 926 [2016]) and, therefore, preservation was required (see People v Brito, 135 AD3d 627, 628-629 [2016], lv denied 27 NY3d 1066 [2016]; People v Simmons, 97 AD3d 842, 843 [2012], lv denied 20 NY3d 935 [2012]; People v Peller, 8 AD3d 1123, 1123-1124 [2004], lv denied 3 NY3d 679 [2004]).

32016–2016
People v. Antoine green
ny · 2016
2 sentences

2016Consequently, we conclude that the court did not violate its core O’Rama responsibilities (see People v Barnes, 139 AD3d 1371, 1372 [2016], lv denied 28 NY3d 926 [2016]) and, therefore, preservation was required (see People v Brito, 135 AD3d 627, 628-629 [2016], lv denied 27 NY3d 1066 [2016]; People v Simmons, 97 AD3d 842, 843 [2012], lv denied 20 NY3d 935 [2012]; People v Peller, 8 AD3d 1123, 1123-1124 [2004], lv denied 3 NY3d 679 [2004]).

2016Consequently, we conclude that the court did not violate its core O’Rama responsibilities (see People v Barnes, 139 AD3d 1371, 1372 [2016], lv denied 28 NY3d 926 [2016]) and, therefore, preservation was required (see People v Brito, 135 AD3d 627, 628-629 [2016], lv denied 27 NY3d 1066 [2016]; People v Simmons, 97 AD3d 842, 843 [2012], lv denied 20 NY3d 935 [2012]; People v Peller, 8 AD3d 1123, 1123-1124 [2004], lv denied 3 NY3d 679 [2004]).

32016–2016
People v. Bailey green
nyappdiv · 1989
2 sentences

1992The defendant waived any claim of error regarding his absence when he failed to object to the questioning procedure (see, People v Torres, 174 AD2d 586 ; People v Gamble, 173 AD2d 555 ; People v Hazzard, 177 AD2d 593 ; People v Grant, 178 AD2d 283 ; People v Bailey, 146 AD2d 788 ).

1991Furthermore, because this was not a material part of the proceedings, the defendant, through his counsel, waived any claim of error regarding his absence (see, CPL 470.05 [2]; United States v Gagnon, 470 US 522 ; People v Mullen, 44 NY2d 1 , 6, supra; People v Bailey, 146 AD2d 788, 789 ).

31991–1992
People v. Vargas green
ny · 1996
2 sentences

2015There, the trial court evaluated the juror's fear for his safety outside the presence of defense counsel and found it to be genuine (see id. at 379 ).

2015There, the trial court evaluated the juror’s fear for his safety outside the presence of defense counsel and found it to be genuine (see id. at 379 ).

22015–2015
Peterson v. Stafford green
scotus · 1993
2 sentences

2015In People v Castillo, an informant's fear justified the court's ex parte proceeding to determine whether to disclose the informer's identity or statements ( 80 NY2d 578, 586 [1992], cert denied 507 US 1033 [1993]).

2015In People v Castillo, an informant’s fear justified the court’s ex parte proceeding to determine whether to disclose the informer’s identity or statements ( 80 NY2d 578, 586 [1992], cert denied 507 US 1033 [1993]).

22015–2015
People v. Sawyer green
nyappdiv · 2008
2 sentences

2013At the hearing, defendant presented his various grounds for withdrawal of his plea in open court, in the presence of defense counsel, and all of defendant’s proffered bases were clearly without merit (see People v Sawyer, 55 AD3d at 950-951 ).

2013At the hearing, defendant presented his various grounds for withdrawal of his plea in open court, in the presence of defense counsel, and all of defendant’s proffered bases were clearly without merit (see People v Sawyer, 55 AD3d at 950-951 ).

22013–2013
O'Leary v. Frangomihalos green
nyappdiv · 2011
2 sentences

2013In light of the mother’s presence at the hearing on October 24, 2011, when her attorney cross-examined the petitioner Alice T., the mother’s actual knowledge of the date and time of the continued hearing, which is undisputed, and her failure to contact her attorney to advise him regarding her failure to appear on the final date of the hearing, the Family Court did not improvidently exercise its discretion in denying the mother’s attorney’s request for an adjournment (cf. Matter of O’Leary v Frangomihalos, 89 AD3d at 949 ; Matter of Kinara C. [Jerome C.], 89 AD3d at 841; Matter of Nicholas S.,

2013In light of the mother’s presence at the hearing on October 24, 2011, when her attorney cross-examined the petitioner Alice T., the mother’s actual knowledge of the date and time of the continued hearing, which is undisputed, and her failure to contact her attorney to advise him regarding her failure to appear on the final date of the hearing, the Family Court did not improvidently exercise its discretion in denying the mother’s attorney’s request for an adjournment (cf. Matter of O’Leary v Frangomihalos, 89 AD3d at 949 ; Matter of Kinara C. [Jerome C.], 89 AD3d at 841; Matter of Nicholas S.,

22013–2013
People v. Pitts neutral
nyappdiv · 2012
2 sentences

2013Accordingly, the sentence must be vacated and the matter remitted to the County Court, Westchester County, for resentencing on the conviction of robbery in the first degree in accordance with CPL 380.20 (see People v McGhee, 96 AD3d 786 [2012]; People v Henry, 80 AD3d 625, 626 [2011]).

2013Accordingly, the sentence must be vacated and the matter remitted to the County Court, Westchester County, for resentencing on the conviction of robbery in the first degree in accordance with CPL 380.20 (see People v McGhee, 96 AD3d 786 [2012]; People v Henry, 80 AD3d 625, 626 [2011]).

22013–2013
People v. Mills green
nyappdiv · 2007
2 sentences

2013Defendant sufficiently articulated his claims such that counsel could have taken action had a meritorious ground been proffered or other intervention been called for (see People v Mills, 45 AD3d at 895-896 ).

2013Defendant sufficiently articulated his claims such that counsel could have taken action had a meritorious ground been proffered or other intervention been called for (see People v Mills, 45 AD3d at 895-896 ).

22013–2013
In re Martha P. green
nyappdiv · 2007
2 sentences

2013In light of the mother’s presence at the hearing on October 24, 2011, when her attorney cross-examined the petitioner Alice T., the mother’s actual knowledge of the date and time of the continued hearing, which is undisputed, and her failure to contact her attorney to advise him regarding her failure to appear on the final date of the hearing, the Family Court did not improvidently exercise its discretion in denying the mother’s attorney’s request for an adjournment (cf. Matter of O’Leary v Frangomihalos, 89 AD3d at 949 ; Matter of Kinara C. [Jerome C.], 89 AD3d at 841; Matter of Nicholas S.,

2013In light of the mother’s presence at the hearing on October 24, 2011, when her attorney cross-examined the petitioner Alice T., the mother’s actual knowledge of the date and time of the continued hearing, which is undisputed, and her failure to contact her attorney to advise him regarding her failure to appear on the final date of the hearing, the Family Court did not improvidently exercise its discretion in denying the mother’s attorney’s request for an adjournment (cf. Matter of O’Leary v Frangomihalos, 89 AD3d at 949 ; Matter of Kinara C. [Jerome C.], 89 AD3d at 841; Matter of Nicholas S.,

22013–2013
People v. McShaw green
nyappdiv · 1994
2 sentences

2012While the trial judge acknowledged that it might be to trial counsel’s “ ‘advantage perhaps to confer’ ” with a supervisor, he nevertheless denied her request because it was the court’s “ ‘practice to exclude everybody.’ ” ( 204 AD2d at 742 .) The Second Department held that the closure of the courtroom to defense counsel’s supervisor was broader than constitutionally permissible, noting that the trial court failed to make findings adequate to justify the closure of the courtroom to the supervising attorneys on the record and failed to indicate that the presence of defense counsel’s supervisor

1995This Court reversed the conviction because the Supreme Court failed to make findings "that the presence of the defense counsel’s supervisors would endanger the undercover officers” (People v Mercer, supra, at 743 ).

21995–2012
People v. Antommarchi green
ny · 1992
21998–2003
People v. Torres green
ny · 1992
21993–1993
People v. Torres green
nyappdiv · 1991
21991–1992
United States v. Gagnon green
scotus · 1985
21991–1992
Rowe v. Washburne green
nyappdiv · 1901
21915–1962
Kelley v. . People of the State of N.Y. green
ny · 1874
21920–1920
Peck v. . Cary green
ny · 1863
21870–1880
Rowe v. Great Atlantic & Pacific Tea Co. green
ny · 1978
12026–2026
Daly v. Sprague green
scotus · 1983
12021–2021
People v. O'Kane green
ny · 2016
12020–2020
People v. Dame green
ny · 2017
12017–2017
People v. Dame green
nyappdiv · 2016
12017–2017
Walton v. New York State Department of Correctional Services green
ny · 2007
12015–2015
Mortensen v. Memorial Hospital green
nyappdiv · 1984
12015–2015
Riverkeeper, Inc. v. Crotty green
nyappdiv · 2006
12015–2015
People v. Armstrong green
nyappterm · 1994
12014–2014
People v. Cajigas green
nyappdiv · 1996
12014–2014
Orvis Co. v. Tax Appeals Tribunal green
ny · 1995
12013–2013
People v. Smikle green
nyappdiv · 2011
12012–2012
People v. Hines green
nyappdiv · 1996
12012–2012
Rothgery v. Gillespie County green
scotus · 2008
12010–2010
People v. Kidd green
nyappdiv · 1994
12005–2005
People v. Brown neutral
nyappdiv · 1998
12003–2003
People v. Rivers green
nyappdiv · 1999
12003–2003
People v. Diaz green
nysupct · 1987
12002–2002
Ungar v. Sarafite green
scotus · 1964
12002–2002
People v. Stevens green
nyappdiv · 1989
12002–2002
People v. Arroyave green
ny · 1980
12002–2002

Statutes the citing opinions construe

NY § N.Y. Penal Law § 140.25 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 168 (1889–2026) NY 126 (1858–2026) IL 120 (1899–2026) TX 110 (1909–2026) AL 86 (1845–2010) PA 83 (1896–2025) WA 56 (1901–2023) GA 56 (1900–2021) MO 52 (1867–2025) WY 47 (1936–2025) TN 41 (1948–2024) IN 38 (1872–2018) LA 36 (1915–2015) NC 32 (1881–2024) MI 32 (1911–2025) OH 31 (1881–2025) NJ 31 (1945–2026) KS 30 (1901–2026) KY 29 (1917–2025) MS 29 (1909–2022) NM 28 (1946–2022) FL 28 (1952–2026) CO 28 (1904–2024) CT 27 (1939–2025) MA 27 (1892–2026) VA 26 (1795–2023) OR 24 (1893–2025) MN 23 (1924–2018) OK 23 (1911–2015) AR 22 (1916–2024) DC 21 (1973–2019) WI 20 (1923–2024) ID 19 (1923–2022) MD 17 (1933–2014) IA 17 (1916–2023) VT 13 (1904–2026) RI 13 (1973–2014) MT 13 (1924–2024) ME 13 (1925–2019) AZ 11 (1920–2009) DE 11 (1981–2025) NE 10 (1905–2020) WV 8 (1981–2003) AK 7 (1972–2019) UT 7 (1985–2024) ND 6 (1971–2023) SD 6 (1913–2013) HI 5 (1977–2021) PR 4 (1918–1966) SC 4 (1936–2016) NH 3 (1951–1995) NV 2 (1987–2021)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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