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 § 135.65 (2026)

Coercion in the first degree

✓ current as of May 2026
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§ 135.65 Coercion in the first degree.
  A person is guilty of coercion in the first degree when he or she
commits the crime of coercion in the third degree, and when:
  1. He or she commits such crime by instilling in the victim a fear
that he or she will cause physical injury to a person or cause damage to
property; or
  2. He or she thereby compels or induces the victim to:
  (a) Commit or attempt to commit a felony; or
  (b) Cause or attempt to cause physical injury to a person; or
  (c) Violate his or her duty as a public servant.
  Coercion in the first degree is a class D felony.
Notes of Decisions
Cited in 36 cases (4 in the last 5 years), 1975–2023 · leading case: United States v. Gurmeet Singh Dhinsa, 243 F.3d 635 (2d Cir. 2001).
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United States v. Gurmeet Singh Dhinsa, 243 F.3d 635 (2d Cir. 2001). · cites it 5× “of kidnapping in aid of racketeering; (5) there was insufficient evidence to support the jury’s convictions for interstate kidnapping; (6) a new trial is warranted on the racketeering counts because Dhinsa’s convictions on a number of the predicate crimes are invalid; (7) there…”
People v. Finkelstein, 68 N.E.3d 64 (NY 2016). · cites it 2× “Defendant was charged with, among other crimes, two counts of coercion in the first degree for threatening his former girlfriend (see Penal Law § 135.65 [1]). Specifically, he threat *348 ened her physically and threatened to ruin her small business after she asked defendant to…”
People v. Leisner, 535 N.E.2d 647 (NY 1989). “65), two counts of coercion in the first degree (Penal Law § 135.65) and two counts of burglary in the third degree (Penal Law § 140.”
People v. Motte, 285 A.D.2d 814 (N.Y. App. Div. 2001). “To be convicted of coercion in the first degree, the People were required to prove that defendant compelled Laware to engage in conduct which she had a legal right to abstain from engaging in by instilling in her a fear that if she did not comply with the demand, defendant would…”
State v. Schweppe, 237 N.W.2d 609 (Minn. 1975). “, N. Y. Penal Law § 135.65 (McKinney 1965); Kan.”
People v. Adams, 50 A.D.3d 433 (N.Y. App. Div. 2008). “Defendant failed to preserve his claim that his conviction of attempted coercion in the first degree violated the principles of Apprendi v New Jersey ( 530 US 466 [2000]), or his claim that the first-degree coercion statute (Penal Law § 135.65 [1]) is unconstitutional because it…”
State Wide Photocopy, Corp. v. Tokai Fin. Servs., Inc., 909 F. Supp. 137 (S.D.N.Y. 1995). “at 1130-1133 (noting essential element of extortion not required in New York coercion statute, N.Y. Penal Law § 135.65 ; since extortion expressly named and coercion excluded from statute, latter not recognized as RICO predicate act); cf.”
People v. Jones, 165 A.D.2d 103 (N.Y. App. Div. 1991). “65 [3]) and coercion in the first degree (Penal Law § 135.65 [2]), and sentencing him to concurrent indeterminate terms of imprisonment of from 7 to 21 years on the rape and sodomy counts, and 2Vz to 7 years on the remaining counts, should be modified, on the law, the facts, and…”
People v. O'Donnell, 2021 NY Slip Op 03709 (N.Y. App. Div. 2021). “Again viewing the evidence independently and in light of the elements of the crimes as charged to the jury ( see Danielson , 9 NY3d at 349 ; Dexter , 191 AD3d at 1246-1247 ), we further agree with defendant that the verdict is against the weight of the evidence on the counts of…”
People v. Williamson, 21 A.D.3d 575 (N.Y. App. Div. 2005). “The People were required to prove that defendant compelled the victim to abstain from calling the police, conduct which she had a legal right to engage in, by instilling in her a fear that he would cause her physical injury if she did not comply with his demand (see Penal Law §…”
People v. Martello, 717 N.E.2d 684 (NY 1999). “20), coercion (Penal Law § 135.65) and related crimes. Following a jury trial, defendant was convicted of one count of attempted coercion in the first degree (Penal Law §§ 110.”
People v. Gonzalez, 173 A.D.2d 48 (N.Y. App. Div. 1991). “50), and coercion in the first degree (Penal Law § 135.65). Thereafter, in the second indictment, number 4885 of 1989, filed on April 19, 1989, a Grand Jury charged defendant with committing the crimes of robbery in the first degree (two counts), and attempted robbery in the…”
Show all 36 citing cases →
— N.Y. Penal Law § 135.65(1) — 1 case
United States v. Private Sanitation Indus. Ass'n of Nassau/Suffolk Inc., 914 F. Supp. 895 (E.D.N.Y 1996).
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