People v. Williams
| Court | New York Court of Appeals Court of Appeals |
| Writing for the Court | KAYE |
| Citation | People v. Williams, 84 N.Y.2d 925, 620 N.Y.S.2d 811, 644 N.E.2d 1367 (N.Y. 1994) |
| Decision Date | 29 November 1994 |
| Parties | , 644 N.E.2d 1367 The PEOPLE of the State of New York, Appellant, v. Jamie WILLIAMS, Respondent. |
The order of the Appellate Division should be reversed, and the case remitted to that court for consideration of the facts (see, CPL 470.25[2][d]; 470.40[2][b] and issues raised by defendant but not considered on the appeal to that court.
The Appellate Division reversed defendant's conviction on the law for insufficient evidence, 198 A.D.2d 804, 604 N.Y.S.2d 390. However, it erroneously reviewed the evidence pursuant to a standard available only to a trier of fact: whether the circumstantial evidence excluded "to a moral certainty" every reasonable hypothesis of innocence. A court reviewing legal sufficiency of the trial evidence must instead determine whether any valid line of reasoning and permissible inferences could lead a rational person to the conclusion reached by the fact finder on the basis of the evidence at trial, viewed in the light most favorable to the People (People v. Wong, 81 N.Y.2d 600, 608, 601 N.Y.S.2d 440, 619 N.E.2d 377; see also People v. Bleakley, 69 N.Y.2d 490, 495, 515 N.Y.S.2d 761, 508 N.E.2d 672). Applying this standard here, we conclude the evidence was sufficient to establish defendant's guilt of manslaughter in the second degree.
Although the evidence established that on the day seven-week-old Jamila Mallette was fatally injured, her mother (Wynonna Mallette) and defendant, together, were alone with the infant, only defendant was charged with causing the child's death (cf., People v. Wong, 81 N.Y.2d 600, 601 N.Y.S.2d 440, 619 N.E.2d 377, supra ). Viewed in the light most favorable to the People, the evidence was sufficient to establish that defendant, rather than Mallette, recklessly caused the child's death. Medical testimony established that the cause of death was blunt force trauma to the abdomen, injury that was not accidental in nature, and there was evidence that infliction of that injury occurred in a time frame during which the infant was alone with defendant.
Defendant gave contradictory statements concerning his contact with the infant during that critical time span, and Mallette testified...
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...52 N.J. 413, 245 A.2d 481 (1968).New Mexico: State v. Bankert, 117 N.M. 614, 875 P.2d 370 (1994).New York: People v. Williams, 84 N.Y.2d 925, 620 N.Y.S.2d 811, 644 N.E.2d 1367 (1994).North Carolina: State v. Haselden, 357 N.C. 1, 577 S.E.2d 594 (2003).North Dakota: State v. Treis, 597 N.W.2......
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...beyond a reasonable doubt (see People v. Danielson, 9 N.Y.3d 342, 349, 849 N.Y.S.2d 480, 880 N.E.2d 1 ; People v. Williams, 84 N.Y.2d 925, 926, 620 N.Y.S.2d 811, 644 N.E.2d 1367 ), as physical injury, pursuant to Penal Law § 10.00(9) was established with evidence that the complainant experi......
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...to the People’ " ( People v. Hines, 97 N.Y.2d 56, 62, 736 N.Y.S.2d 643, 762 N.E.2d 329 [2001], quoting People v. Williams, 84 N.Y.2d 925, 926, 620 N.Y.S.2d 811, 644 N.E.2d 1367 [1994] ; accord People v. Reichel, 110 A.D.3d 1356, 1363, 975 N.Y.S.2d 470 [2013], lv denied 22 N.Y.3d 1090, 981 N......
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...643, 762 N.E.2d 329; People v. Norman, 85 N.Y.2d 609, 620–622, 627 N.Y.S.2d 302, 650 N.E.2d 1303 [1995]; People v. Williams, 84 N.Y.2d 925, 926, 620 N.Y.S.2d 811, 644 N.E.2d 1367 [1994]; see also People v. Rossey, 89 N.Y.2d 970, 971–972, 655 N.Y.S.2d 861, 678 N.E.2d 473 [1997]; People v. Wo......
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