N.Y. Laws » CHAPTER Penal / PART Specific Offenses / TITLE Offenses Against the Person Involving Physical Injury, Sexual Conduct, Restraint and Intimidation / ARTICLE Kidnapping, Coercion and Related Offenses
New York Consolidated Laws

N.Y. Penal Law § 135.10 (2026)

Unlawful imprisonment in the first degree

✓ current as of May 2026
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§ 135.10 Unlawful imprisonment in the first degree.
  A person is guilty of unlawful imprisonment in the first degree when
he restrains another person under circumstances which expose the latter
to a risk of serious physical injury.
  Unlawful imprisonment in the first degree is a class E felony.
Notes of Decisions
Cited in 76 cases (6 in the last 5 years), 1977–2026 · leading case: The People v. Quanaparker Howard, 52 N.E.3d 1158 (NY 2016).
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The People v. Quanaparker Howard, 52 N.E.3d 1158 (NY 2016). · cites it 2× “Defendant was convicted of first-degree unlawful imprisonment (Penal Law § 135.10), two counts of first- degree assault (id.”
People v. Gonzalez, 603 N.E.2d 938 (NY 1992). · cites it 2× “20) and the lesser crimes of unlawful imprisonment, also in the first and second degrees (see, Penal Law §§ 135.10, 135.05; see generally, Donnino, Practice Commentaries, McKinney’s Cons Laws of NY, Book 39, Penal Law § 135.”
John P. Dickson v. John Ashcroft, Attorney Gen. of the United States of Am., 346 F.3d 44 (2d Cir. 2003). “In December 2000, Dickson pled guilty to unlawful imprisonment in the first degree, pursuant to N.Y. Penal Law § 135.10 (McKinney 2003) (“NYPL § 135.”
People v. Dunbar, 23 N.E.3d 946 (NY 2014). “15), unlawful imprisonment in the first degree (Penal Law § 135.10), criminal possession of a weapon in the third degree (Penal Law § 265.”
Luis Vargas-Sarmiento v. United States Dep't of Just., Bureau of Citizenship & Immigr. Servs., 448 F.3d 159 (2d Cir. 2006). “3d at 51 (holding that, even if none of the elements of unlawful imprisonment under N.Y. Penal Law § 135.10 expressly require the use of physical force, the offense still satisfies 18 U.”
United States v. Gonzalez-Ramirez, 477 F.3d 310 (5th Cir. 2007). “§ 53a-95 (West 2001) (defining unlawful restraint in the first degree as restraint "under circumstances which expose [the victim] to a substantial risk of physical injury”); N.Y. Penal Law § 135.10 (McKinney 2004) (defining unlawful imprisonment in the first degree as requiring…”
People v. Irby, 140 A.D.3d 1319 (N.Y. App. Div. 2016). ““A person is guilty of unlawful imprisonment in the first degree when he [or she] restrains another person under circumstances which expose the latter to a risk of serious physical injury” (Penal Law § 135.10). Insofar as is relevant here, the restraint element “means to…”
Anthony Reid v. Daniel A. Senkowski, Superintendent, Clinton Corr. Facility, 961 F.2d 374 (2d Cir. 1992). “15 [4] and four counts of unlawful imprisonment in the first degree in violation of N.Y. Penal Law § 135.10 . The New York Appellate Division affirmed the conviction, see People v.”
People v. Kruppenbacher, 81 A.D.3d 1169 (N.Y. App. Div. 2011). “As for unlawful imprisonment, the prosecution was required to establish that defendant restrained the victim “under circumstances which expose[d her] to a risk of serious physical injury” (Penal Law § 135.10). Here, each victim testified to being forcibly confined to defendant’s…”
Velazquez v. Poole, 614 F. Supp. 2d 284 (E.D.N.Y 2007). “65[1]; Unlawful Imprisonment in the First Degree, in violation of Penal Law § 135.10; Endangering the Welfare of a Child, in violation of Penal Law § 260.”
People v. Wright, 107 A.D.3d 1398 (N.Y. App. Div. 2013). “With respect to count 10, charging defendant with unlawful imprisonment in the first degree as a hate crime (Penal Law §§ 135.10, 485.05 [1] [b]), we agree with defendant that the evidence is legally insufficient to support the hate crime element of the conviction.”
People v. Cintron, 13 Misc. 3d 833 (N.Y. Sup. Ct. 2006). “Kidnapping is defined as abducting another person (Penal Law § 135.20). Unlawful imprisonment is defined as restraining another person under circumstances which expose the latter to a risk of serious physical injury (Penal Law § 135.”
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