LeGrand analysis (New York) · Go Syfert
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LeGrand analysis in New York

8 New York opinions name it 2 courts 2010–2024 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 (3)

CaseFollowedCited
People v. Santiagogreen
ny · 2011 · cited in 6 New York opinions naming this issue, 2015–2024
2 sentences

2024Footnote 15: As one New York jurist has suggested, Holmes throws the constitutionality of permitting consideration of the prosecution's corroboration completely into doubt ( People v Santiago , 75 AD3d 163, 177 [1st Dept 2010] [McGuire, J., concurring], revd , 17 NY3d at 673 [holding, pre- McCullough , that the prosecution's corroborating evidence was not "sufficient to obviate the second stage of the LeGrand analysis"]).

2024Footnote 15: As one New York jurist has suggested, Holmes throws the constitutionality of permitting consideration of the prosecution's corroboration completely into doubt ( People v Santiago , 75 AD3d 163, 177 [1st Dept 2010] [McGuire, J., concurring], revd , 17 NY3d at 673 [holding, pre- McCullough , that the prosecution's corroborating evidence was not "sufficient to obviate the second stage of the LeGrand analysis"]).

36
People v. LeGrandgreen
ny · 2007 · cited in 4 New York opinions naming this issue, 2010–2015
2 sentences

2015Although “the case turns on the accuracy of [the] eyewitness identification[ ]” (People v LeGrand, 8 NY3d 449, 452 [2007]), we conclude that the identification of defendant by the eyewitness was corroborated by the reliable testimony of the accomplice, and thus we disagree with the majority that an analysis of the factors in the second stage of the LeGrand analysis is necessary (see generally People v Santiago, 17 NY3d 661, 669 [2011]).

2015Although “the case turns on the accuracy of [the] eyewitness identification[ ]” (People v LeGrand, 8 NY3d 449, 452 [2007]), we conclude that the identification of defendant by the eyewitness was corroborated by the reliable testimony of the accomplice, and thus we disagree with the majority that an analysis of the factors in the second stage of the LeGrand analysis is necessary (see generally People v Santiago, 17 NY3d 661, 669 [2011]).

24
People v. Santiagogreen
nyappdiv · 2010 · cited in 1 New York opinions naming this issue, 2024–2024
2 sentences

2024Footnote 15: As one New York jurist has suggested, Holmes throws the constitutionality of permitting consideration of the prosecution's corroboration completely into doubt ( People v Santiago , 75 AD3d 163, 177 [1st Dept 2010] [McGuire, J., concurring], revd , 17 NY3d at 673 [holding, pre- McCullough , that the prosecution's corroborating evidence was not "sufficient to obviate the second stage of the LeGrand analysis"]).

2024Footnote 15: As one New York jurist has suggested, Holmes throws the constitutionality of permitting consideration of the prosecution's corroboration completely into doubt ( People v Santiago , 75 AD3d 163, 177 [1st Dept 2010] [McGuire, J., concurring], revd , 17 NY3d at 673 [holding, pre- McCullough , that the prosecution's corroborating evidence was not "sufficient to obviate the second stage of the LeGrand analysis"]).

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 (2)

CaseCitedYears
People v. Muhammad green
ny · 2011
2 sentences

2015With respect to the second stage of the analysis, we conclude that the proposed testimony “satisfies the general criteria for the admissibility of expert proof” (Muhammad, 17 NY3d at 546 ), i.e., it is “ ‘(1) relevant to the witness’s identification of defendant, (2) based on principles that are generally accepted within the relevant scientific community, (3) proffered by a qualified expert and (4) on a topic beyond the ken of the average juror’ ” (Santiago, 17 NY3d at 669 , quoting LeGrand, 8 NY3d at 452 ).

2015With respect to the second stage of the analysis, we conclude that the proposed testimony “satisfies the general criteria for the admissibility of expert proof” (Muhammad, 17 NY3d at 546 ), i.e., it is “ ‘(1) relevant to the witness’s identification of defendant, (2) based on principles that are generally accepted within the relevant scientific community, (3) proffered by a qualified expert and (4) on a topic beyond the ken of the average juror’ ” (Santiago, 17 NY3d at 669 , quoting LeGrand, 8 NY3d at 452 ).

32015–2015
People v. Abney green
ny · 2009
2 sentences

2011And defendant was not a stranger to either [eyewitness].” ( 13 NY3d at 269 .) Whether a victim’s or other eyewitness’s identification of a defendant is sufficiently corroborated by other eyewitness identifications, so that the trial court need not proceed to the second stage of the LeGrand analysis, is dependent on the circumstances of the case.

2011And defendant was not a stranger to either [eyewitness].” ( 13 NY3d at 269 .) Whether a victim’s or other eyewitness’s identification of a defendant is sufficiently corroborated by other eyewitness identifications, so that the trial court need not proceed to the second stage of the LeGrand analysis, is dependent on the circumstances of the case.

12011–2011

Statutes the citing opinions construe

NY § N.Y. Penal Law § 125.25 (3)

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.

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