lesser included offense instruction (New York) · Go Syfert
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lesser included offense instruction in New York

10 New York opinions name it 3 courts 1978–2023 1 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 (15)

CaseFollowedCited
People v. Henriquezgreen
ny · 2004 · cited in 1 New York opinions naming this issue, 2010–2010
1 sentence

2010The ABA Standards implicitly recognize that the conclusion reached will not always comport with the advice of counsel, but counsel’s acquiescence to his client’s decision does not render counsel’s representation constitutionally ineffective (see Coleman v Mitchell, 244 F3d 533, 545 [2001], cert denied 534 US 977 [2001]; Ex parte Mills, — So 3d —, 2010 WL 3463487 , 2010 Ala LEXIS 157 [Ala 2010] [stating that a reading of the ABA Standards does not support the conclusion that the defendant may never make the ultimate decision regarding a matter of trial strategy such as whether to submit a lesse

11
People v. Vargasgreen
nyappdiv · 1989 · cited in 1 New York opinions naming this issue, 2010–2010
1 sentence

2010Had there been no disagreement, counsel’s decision to seek the submission of lesser-included offenses, or not, could be justified as a strategic decision of a reasonably competent attorney (see People v Lane, 60 NY2d 748, 750 [1983]; People v Calderon, 66 AD3d 314 , 320 [2009]; People v Illescas, 47 AD3d 840, 841 [2008]; People v Koufomichalis, 2 AD3d 987, 989 [2003]; People v Drummond, 188 AD2d 312 [1992]; People v Vargas, 150 AD2d 513, 514 [1989]).

11
Alton Coleman v. Betty Mitchell, Wardengreen
ca6 · 2001 · cited in 1 New York opinions naming this issue, 2010–2010
1 sentence

2010The ABA Standards implicitly recognize that the conclusion reached will not always comport with the advice of counsel, but counsel’s acquiescence to his client’s decision does not render counsel’s representation constitutionally ineffective (see Coleman v Mitchell, 244 F3d 533, 545 [2001], cert denied 534 US 977 [2001]; Ex parte Mills, — So 3d —, 2010 WL 3463487 , 2010 Ala LEXIS 157 [Ala 2010] [stating that a reading of the ABA Standards does not support the conclusion that the defendant may never make the ultimate decision regarding a matter of trial strategy such as whether to submit a lesse

11
People v. Koufomichalisgreen
nyappdiv · 2003 · cited in 1 New York opinions naming this issue, 2010–2010
1 sentence

2010Had there been no disagreement, counsel’s decision to seek the submission of lesser-included offenses, or not, could be justified as a strategic decision of a reasonably competent attorney (see People v Lane, 60 NY2d 748, 750 [1983]; People v Calderon, 66 AD3d 314 , 320 [2009]; People v Illescas, 47 AD3d 840, 841 [2008]; People v Koufomichalis, 2 AD3d 987, 989 [2003]; People v Drummond, 188 AD2d 312 [1992]; People v Vargas, 150 AD2d 513, 514 [1989]).

11
People v. Hoffmangreen
nyappdiv · 2008 · cited in 1 New York opinions naming this issue, 2010–2010
1 sentence

2010Had there been no disagreement, counsel’s decision to seek the submission of lesser-included offenses, or not, could be justified as a strategic decision of a reasonably competent attorney (see People v Lane, 60 NY2d 748, 750 [1983]; People v Calderon, 66 AD3d 314 , 320 [2009]; People v Illescas, 47 AD3d 840, 841 [2008]; People v Koufomichalis, 2 AD3d 987, 989 [2003]; People v Drummond, 188 AD2d 312 [1992]; People v Vargas, 150 AD2d 513, 514 [1989]).

11
People v. Lanegreen
ny · 1983 · cited in 1 New York opinions naming this issue, 2010–2010
1 sentence

2010Had there been no disagreement, counsel’s decision to seek the submission of lesser-included offenses, or not, could be justified as a strategic decision of a reasonably competent attorney (see People v Lane, 60 NY2d 748, 750 [1983]; People v Calderon, 66 AD3d 314 , 320 [2009]; People v Illescas, 47 AD3d 840, 841 [2008]; People v Koufomichalis, 2 AD3d 987, 989 [2003]; People v Drummond, 188 AD2d 312 [1992]; People v Vargas, 150 AD2d 513, 514 [1989]).

11
People v. Morangreen
ny · 1927 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004While a defendant’s request to charge a lesser included offense need not be granted in every case (see People v Scarborough, 49 NY2d 364, 368 [1980]; People v Alston [Baby John], 298 AD2d 702, 703 [2002], lvs denied 99 NY2d 554 , 555 [2002]; People v McNeil, 273 AD2d 608, 609-610 [2000], lv denied 95 NY2d 868 [2000]), “[t]o warrant a refusal to submit it ‘every possible hypothesis’ but guilt of the higher crime must be excluded” (People v Henderson, supra at 236, quoting People v Shuman, 37 NY2d 302, 304 [1975]; see People v Asan, 22 NY2d 526, 530 [1968]; People v Moran, 246 NY 100, 103 [1927]

11
People v. Asangreen
ny · 1968 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004While a defendant’s request to charge a lesser included offense need not be granted in every case (see People v Scarborough, 49 NY2d 364, 368 [1980]; People v Alston [Baby John], 298 AD2d 702, 703 [2002], lvs denied 99 NY2d 554 , 555 [2002]; People v McNeil, 273 AD2d 608, 609-610 [2000], lv denied 95 NY2d 868 [2000]), “[t]o warrant a refusal to submit it ‘every possible hypothesis’ but guilt of the higher crime must be excluded” (People v Henderson, supra at 236, quoting People v Shuman, 37 NY2d 302, 304 [1975]; see People v Asan, 22 NY2d 526, 530 [1968]; People v Moran, 246 NY 100, 103 [1927]

11
People v. Johnsongreen
ny · 1978 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004When considering the second prong of the lesser included offense test, the evidence is viewed in the light most favorable to the defendant (see People v Johnson, 45 NY2d 546, 550 [1978]; see also People v Ford, 66 NY2d 428, 439-440 [1985]) and the trial court’s “appraisal of the persuasiveness of the evidence indicating guilt of the higher count is irrelevant” (People v Henderson, supra at 236).

11
People v. McNeilgreen
nyappdiv · 2000 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004While a defendant’s request to charge a lesser included offense need not be granted in every case (see People v Scarborough, 49 NY2d 364, 368 [1980]; People v Alston [Baby John], 298 AD2d 702, 703 [2002], lvs denied 99 NY2d 554 , 555 [2002]; People v McNeil, 273 AD2d 608, 609-610 [2000], lv denied 95 NY2d 868 [2000]), “[t]o warrant a refusal to submit it ‘every possible hypothesis’ but guilt of the higher crime must be excluded” (People v Henderson, supra at 236, quoting People v Shuman, 37 NY2d 302, 304 [1975]; see People v Asan, 22 NY2d 526, 530 [1968]; People v Moran, 246 NY 100, 103 [1927]

11
People v. Shumangreen
ny · 1975 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004While a defendant’s request to charge a lesser included offense need not be granted in every case (see People v Scarborough, 49 NY2d 364, 368 [1980]; People v Alston [Baby John], 298 AD2d 702, 703 [2002], lvs denied 99 NY2d 554 , 555 [2002]; People v McNeil, 273 AD2d 608, 609-610 [2000], lv denied 95 NY2d 868 [2000]), “[t]o warrant a refusal to submit it ‘every possible hypothesis’ but guilt of the higher crime must be excluded” (People v Henderson, supra at 236, quoting People v Shuman, 37 NY2d 302, 304 [1975]; see People v Asan, 22 NY2d 526, 530 [1968]; People v Moran, 246 NY 100, 103 [1927]

11
People v. Alstongreen
nyappdiv · 2002 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004While a defendant’s request to charge a lesser included offense need not be granted in every case (see People v Scarborough, 49 NY2d 364, 368 [1980]; People v Alston [Baby John], 298 AD2d 702, 703 [2002], lvs denied 99 NY2d 554 , 555 [2002]; People v McNeil, 273 AD2d 608, 609-610 [2000], lv denied 95 NY2d 868 [2000]), “[t]o warrant a refusal to submit it ‘every possible hypothesis’ but guilt of the higher crime must be excluded” (People v Henderson, supra at 236, quoting People v Shuman, 37 NY2d 302, 304 [1975]; see People v Asan, 22 NY2d 526, 530 [1968]; People v Moran, 246 NY 100, 103 [1927]

11
People v. Scarboroughgreen
ny · 1980 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004While a defendant’s request to charge a lesser included offense need not be granted in every case (see People v Scarborough, 49 NY2d 364, 368 [1980]; People v Alston [Baby John], 298 AD2d 702, 703 [2002], lvs denied 99 NY2d 554 , 555 [2002]; People v McNeil, 273 AD2d 608, 609-610 [2000], lv denied 95 NY2d 868 [2000]), “[t]o warrant a refusal to submit it ‘every possible hypothesis’ but guilt of the higher crime must be excluded” (People v Henderson, supra at 236, quoting People v Shuman, 37 NY2d 302, 304 [1975]; see People v Asan, 22 NY2d 526, 530 [1968]; People v Moran, 246 NY 100, 103 [1927]

11
People v. Fordgreen
ny · 1985 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004When considering the second prong of the lesser included offense test, the evidence is viewed in the light most favorable to the defendant (see People v Johnson, 45 NY2d 546, 550 [1978]; see also People v Ford, 66 NY2d 428, 439-440 [1985]) and the trial court’s “appraisal of the persuasiveness of the evidence indicating guilt of the higher count is irrelevant” (People v Henderson, supra at 236).

11
Keeble v. United Statesgreen
scotus · 1973 · cited in 1 New York opinions naming this issue, 1998–1998
1 sentence

1998(See, e.g., Beck v Alabama, 447 US, supra, at 637 [1980] [“While we have never held that a defendant is entitled to a lesser included offense instruction as a matter of due process, the nearly universal acceptance of the rule in both state and federal courts establishes the value to the defendant of this procedural safeguard”]; Keeble v United States, 412 US 205, 213 [1973] [“Indeed, while we have never explicitly held that the Due Process Clause of the Fifth Amendment guarantees the right of a defendant to have the jury instructed on a lesser included offense, it is nevertheless clear that a

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 (14)

CaseCitedYears
People v. Colville green
ny · 2012
1 sentence

2023Here, defense counsel made a tactical decision not to seek the lesser included offense ( see id. at 31 - 32).

12023–2023
People v. Miller green
ny · 2006
2 sentences

2014And, in the event that the jury ignores the instructions and convicts the defendant of both the hate crime and the corresponding ordinary crime, the court may eliminate excessive punishment by dismissing the non- hate crime count as an inclusory concurrent offense (see CPL 300.40 [3] [b]; Miller, 6 NY3d at 303-304 ).

2014And, in the event that the jury ignores the instructions and convicts the defendant of both the hate crime and the corresponding ordinary crime, the court may eliminate excessive punishment by dismissing the non-hate crime count as an inclusory concurrent offense (see CPL 300.40 [3] [b]; Miller, 6 NY3d at 303-304 ).

12014–2014
Newsome v. Entergy Services, Inc. green
scotus · 2001
1 sentence

2010The ABA Standards implicitly recognize that the conclusion reached will not always comport with the advice of counsel, but counsel’s acquiescence to his client’s decision does not render counsel’s representation constitutionally ineffective (see Coleman v Mitchell, 244 F3d 533, 545 [2001], cert denied 534 US 977 [2001]; Ex parte Mills, — So 3d —, 2010 WL 3463487 , 2010 Ala LEXIS 157 [Ala 2010] [stating that a reading of the ABA Standards does not support the conclusion that the defendant may never make the ultimate decision regarding a matter of trial strategy such as whether to submit a lesse

12010–2010
People v. Drummond green
nyappdiv · 1992
1 sentence

2010Had there been no disagreement, counsel’s decision to seek the submission of lesser-included offenses, or not, could be justified as a strategic decision of a reasonably competent attorney (see People v Lane, 60 NY2d 748, 750 [1983]; People v Calderon, 66 AD3d 314 , 320 [2009]; People v Illescas, 47 AD3d 840, 841 [2008]; People v Koufomichalis, 2 AD3d 987, 989 [2003]; People v Drummond, 188 AD2d 312 [1992]; People v Vargas, 150 AD2d 513, 514 [1989]).

12010–2010
Ex Parte Mills green
ala · 2010
1 sentence

2010The ABA Standards implicitly recognize that the conclusion reached will not always comport with the advice of counsel, but counsel’s acquiescence to his client’s decision does not render counsel’s representation constitutionally ineffective (see Coleman v Mitchell, 244 F3d 533, 545 [2001], cert denied 534 US 977 [2001]; Ex parte Mills, — So 3d —, 2010 WL 3463487 , 2010 Ala LEXIS 157 [Ala 2010] [stating that a reading of the ABA Standards does not support the conclusion that the defendant may never make the ultimate decision regarding a matter of trial strategy such as whether to submit a lesse

12010–2010
Beck v. Alabama green
scotus · 1980
1 sentence

2002Thus, if the unavailability of a lesser included offense instruction enhances the risk of an unwarranted conviction, Alabama is constitutionally prohibited from withdrawing that option from the jury in a capital case” ( 447 US at 638 ).

12002–2002
People v. Mussenden green
ny · 1955
2 sentences

1986IV In discussing the lesser included offense doctrine, our Court of Appeals noted in People v Mussenden ( 308 NY 558, 562 , supra), that the doctrine indirectly "redounds to the benefit of defendants * * * since its effect actually is to empower the jury 'to extend mercy to an accused by finding a lesser degree of crime than is established by the evidence’ However, the court stressed that the "proper function or duty” of the jury consists "solely of applying the legal definitions of crime, as laid down by the trial court, to the evidence and of convicting of the crime charged, if that is estab

1986IV In discussing the lesser included offense doctrine, our Court of Appeals noted in People v Mussenden ( 308 NY 558, 562 , supra), that the doctrine indirectly "redounds to the benefit of defendants * * * since its effect actually is to empower the jury 'to extend mercy to an accused by finding a lesser degree of crime than is established by the evidence’ However, the court stressed that the "proper function or duty” of the jury consists "solely of applying the legal definitions of crime, as laid down by the trial court, to the evidence and of convicting of the crime charged, if that is estab

11986–1986
People v. Glover green
ny · 1982
1 sentence

1984Thus, under our holding in People v Glover ( 57 NY2d 61 ), a defendant is entitled to a lesser included offense instruction only if it is impossible to commit the offense charged in the indictment without by the same conduct committing the lesser offense.

11984–1984
Schacherbauer v. University Associates in Obstetrics & Gynecology neutral
nyappdiv · 2008
1 sentence

1978(See, e.g., People v Buchanan, 57 AD2d 781 [possession of a weapon as inclusory concurrent count of murder and robbery]; People v Williams, 57 AD2d 850 [possession of a weapon as inclusory concurrent count of attempted murder]; People v Davis, 56 AD2d 892 [possession of weapon as inclusory concurrent count of attempted assault]; People v Lucas, 56 AD2d 780 [possession of weapon as inclusory concurrent count of robbery]; People v Solomon, 56 AD2d 751 [possession of weapon as inclusory concurrent count of robbery].) The apparent rationale for the dismissal of an indictment count charging possess

11978–1978
Knight v. Dormitory Authority neutral
nyappdiv · 2008
1 sentence

1978(See, e.g., People v Buchanan, 57 AD2d 781 [possession of a weapon as inclusory concurrent count of murder and robbery]; People v Williams, 57 AD2d 850 [possession of a weapon as inclusory concurrent count of attempted murder]; People v Davis, 56 AD2d 892 [possession of weapon as inclusory concurrent count of attempted assault]; People v Lucas, 56 AD2d 780 [possession of weapon as inclusory concurrent count of robbery]; People v Solomon, 56 AD2d 751 [possession of weapon as inclusory concurrent count of robbery].) The apparent rationale for the dismissal of an indictment count charging possess

11978–1978
People v. Ruffin neutral
nyappdiv · 2008
1 sentence

1978(See, e.g., People v Buchanan, 57 AD2d 781 [possession of a weapon as inclusory concurrent count of murder and robbery]; People v Williams, 57 AD2d 850 [possession of a weapon as inclusory concurrent count of attempted murder]; People v Davis, 56 AD2d 892 [possession of weapon as inclusory concurrent count of attempted assault]; People v Lucas, 56 AD2d 780 [possession of weapon as inclusory concurrent count of robbery]; People v Solomon, 56 AD2d 751 [possession of weapon as inclusory concurrent count of robbery].) The apparent rationale for the dismissal of an indictment count charging possess

11978–1978
Sable v. Surowitz neutral
nyappdiv · 1977
1 sentence

1978(See, e.g., People v Buchanan, 57 AD2d 781 [possession of a weapon as inclusory concurrent count of murder and robbery]; People v Williams, 57 AD2d 850 [possession of a weapon as inclusory concurrent count of attempted murder]; People v Davis, 56 AD2d 892 [possession of weapon as inclusory concurrent count of attempted assault]; People v Lucas, 56 AD2d 780 [possession of weapon as inclusory concurrent count of robbery]; People v Solomon, 56 AD2d 751 [possession of weapon as inclusory concurrent count of robbery].) The apparent rationale for the dismissal of an indictment count charging possess

11978–1978
People v. Tobias green
nyappdiv · 1977
1 sentence

1978(See, e.g., People v Buchanan, 57 AD2d 781 [possession of a weapon as inclusory concurrent count of murder and robbery]; People v Williams, 57 AD2d 850 [possession of a weapon as inclusory concurrent count of attempted murder]; People v Davis, 56 AD2d 892 [possession of weapon as inclusory concurrent count of attempted assault]; People v Lucas, 56 AD2d 780 [possession of weapon as inclusory concurrent count of robbery]; People v Solomon, 56 AD2d 751 [possession of weapon as inclusory concurrent count of robbery].) The apparent rationale for the dismissal of an indictment count charging possess

11978–1978
People v. Salemmo green
ny · 1976
1 sentence

1978To be distinguished is the factual situation presented in Salemmo (supra), in which the jury returned a verdict convicting the defendant of criminal sale of a dangerous drug and possession of a dangerous drug with intent to sell, but acquitting him of simple possession.

11978–1978

Where else courts name it

TX 965 (1980–2026) MS 391 (1984–2026) IL 242 (1978–2026) WA 237 (1977–2026) CA 200 (1975–2026) OH 191 (1975–2026) TN 156 (1995–2026) MO 139 (1976–2025) KS 123 (1978–2026) AZ 101 (1979–2025) IN 88 (1974–2024) NM 83 (1979–2025) UT 75 (1982–2026) DC 67 (1975–2021) CT 65 (1980–2025) WI 60 (1984–2025) AL 56 (1982–2024) MI 55 (1966–2025) NC 54 (1980–2026) WY 52 (1978–2024) AR 51 (1984–2026) MT 47 (1978–2025) KY 47 (1993–2025) WV 46 (1981–2026) NJ 45 (1979–2025) CO 44 (1974–2026) MN 39 (1976–2026) MA 39 (1984–2025) VA 33 (1976–2025) FL 32 (1972–2021) NE 31 (1982–2025) OK 27 (1981–2020) OR 25 (1970–2016) ND 23 (1977–2025) AK 23 (1979–2025) IA 23 (1980–2025) HI 23 (1980–2026) RI 22 (1981–2026) DE 20 (1992–2025) PA 19 (1975–2016) SD 19 (1986–2019) SC 17 (1985–2023) MD 17 (1989–2024) NV 17 (1994–2019) LA 14 (1982–2026) VT 12 (1981–2019) NH 12 (1979–2020) NY 10 (1978–2023) ID 8 (1983–2022) GA 7 (1982–2011) ME 3 (2007–2025) GU 2 (2024–2024)

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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