People v. Brown

Summary

The court unanimously affirmed the defendant’s conviction for third-degree criminal possession of a controlled substance and his sentence as a second felony offender. It held that the evidence was sufficient and not against the weight of the evidence, rejected or found unpreserved the defendant’s evidentiary and ineffective-assistance claims, and found the remaining contentions meritless.

Holdings

1. Defendant's guilt was proven beyond a reasonable doubt by overwhelming evidence, and the verdict was not against the weight of the evidence.
2. The challenged testimony and references were admissible as narrative information explaining why police targeted defendant for observation.
3. Defendant's claim concerning the absence of a limiting instruction was unpreserved because defendant never requested such an instruction at trial.
4. On the present record, defendant was not shown to have been denied meaningful representation.

Questions Presented

1. Whether defendant's guilt was proven beyond a reasonable doubt and whether the verdict was against the weight of the evidence.
2. Whether testimony concerning defendant's hand-to-hand exchanges and references to the area as a drug-prone location were improperly admitted.
3. Whether the absence of a limiting-instruction request preserved defendant's challenge to the evidence.
4. Whether defendant established ineffective assistance of trial counsel on the appellate record.

Disposition

affirmed