New York Consolidated Laws
N.Y. Penal Law § 135.60 (2026)
Coercion in the third degree
✓ current as of May 2026
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§ 135.60 Coercion in the third degree. A person is guilty of coercion in the third degree when he or she compels or induces a person to engage in conduct which the latter has a legal right to abstain from engaging in, or to abstain from engaging in conduct in which he or she has a legal right to engage, or compels or induces a person to join a group, organization or criminal enterprise which such latter person has a right to abstain from joining, or compels or induces a person to produce, disseminate, or otherwise display an image or images depicting nudity of such person or depicting such person engaged in sexual conduct as defined in subdivisions two and three of section 235.20 of this chapter, by means of instilling in him or her a fear that, if the demand is not complied with, the actor or another will: 1. Cause physical injury to a person; or 2. Cause damage to property; or 3. Engage in other conduct constituting a crime; or 4. Accuse some person of a crime or cause criminal charges to be instituted against him or her; or 5. Expose a secret or publicize an asserted fact, whether true or false, tending to subject some person to hatred, contempt or ridicule; or 6. Cause a strike, boycott or other collective labor group action injurious to some person's business; except that such a threat shall not be deemed coercive when the act or omission compelled is for the benefit of the group in whose interest the actor purports to act; or 7. Testify or provide information or withhold testimony or information with respect to another's legal claim or defense; or 8. Use or abuse his or her position as a public servant by performing some act within or related to his or her official duties, or by failing or refusing to perform an official duty, in such manner as to affect some person adversely; or 9. Perform any other act which would not in itself materially benefit the actor but which is calculated to harm another person materially with respect to his or her health, safety, business, calling, career, financial condition, reputation or personal relationships. 10. Report his or her immigration status or suspected immigration status. Coercion in the third degree is a class A misdemeanor.
Notes of Decisions
Cited in 47
cases (7 in the last 5 years), 1969–2025 · leading case: United States v. Gurmeet Singh Dhinsa, 243 F.3d 635 (2d Cir. 2001).
United States v. Gurmeet Singh Dhinsa, 243 F.3d 635 (2d Cir. 2001). “See N.Y. Penal Law § 135.60 . We agree. Dhinsa further argues that this Court may not affirm his conviction on count 11 based on the lesser offense of attempted coercion in the first degree because the jury was not asked to consider that offense.”
Matter of Linda H. v. Ahmed S., 2020 NY Slip Op 06951 (N.Y. App. Div. 2020). “), entered on or about March 13, 2018, which, after a trial, to the extent appealed from as limited by the briefs, dismissed all but two alleged family offenses, coercion (Penal Law §135.60) and sexual misconduct (Penal Law §130.”
People v. Finkelstein, 68 N.E.3d 64 (NY 2016). “At trial, defendant requested that the jury be instructed on the crime of coercion in the second degree (Penal Law § 135.60) as a lesser included offense of coercion in the first degree.”
United States v. Kirsch, 903 F.3d 213 (2d Cir. 2018). “16 In contrast, Kirsch sought to extort property that Local 17 members could clearly "obtain": wages and benefits from construction contractors.”
People v. Feldman, 7 Misc. 3d 794 (N.Y. Sup. Ct. 2005). “The ninth and tenth counts charge the defendants with coercion in the second degree (Penal Law § 135.60 [9]) and conspiracy in the sixth degree (Penal Law § 105.”
People v. Greaves, 1 A.D.2d 979 (N.Y. App. Div. 2003). “Contrary to defendant’s contention, it is well established that coercion in the second degree (Penal Law § 135.60) is not a lesser included offense of rape in the first degree (see People v Thurston, 167 AD2d 964, 964-965 [1990], lv denied 79 NY2d 924 [1992]; People v Corley,…”
Wilkinson v. Lewis, 289 F. Supp. 3d 371 (N.D.N.Y. 2018). “" N.Y. Penal Law § 135.60 (9). Defendants have not established on the undisputed material facts that they are entitled to judgment as a matter of law.”
Mario R. Liberta v. Walter R. Kelly, Superintendent, Attica Corr. Facility, 839 F.2d 77 (2d Cir. 1988). “See N.Y. Penal Law §§ 135.60 -.65 (McKinney 1987).”
People v. Feerick, 241 A.D.2d 126 (N.Y. App. Div. 1998). “All four defendants were charged with four counts of coercion in the second degree (Penal Law § 135.60 [8]), each relating to one complainant, alleging in unadorned phrasing that each defendant compelled a complainant to engage in conduct that they had a legal right to abstain…”
People v. Bens, 5 A.D.3d 391 (N.Y. App. Div. 2004). “As the People correctly concede, the conviction of coercion in the first degree was not supported by legally sufficient evidence, since the defendant’s statements to the landlady’s son that his family was in danger did not succeed in compelling or inducing the son to return the…”
People v. Singh, 109 A.D.3d 1010 (N.Y. App. Div. 2013). “[p]erform any other act which would not in itself materially benefit the actor but which is calculated to harm another person materially with respect to his or her health, safety, business, calling, career, financial condition, reputation or personal relationships” (Penal Law §…”
Thoreson v. Penthouse Int'l, Ltd., 55 Empl. Prac. Dec. (CCH) 40,457 (N.Y. Sup. Ct. 1990). “, Penal Law §§ 135.60, 230.30 [1].) Protection for the societal interests implicated by defendant’s conduct is suggested not only by the traditional punitive damages doctrine, but by the HRL itself.”
— N.Y. Penal Law § 135.60(8) — 1 case
People v. Carney, 2020 NY Slip Op 1633 (N.Y. App. Div. 2020).
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