People v. Bender

Summary

The New York Court of Appeals held that the evidence was legally sufficient to support Donald Bender's conviction for first-degree reckless endangerment based on conduct demonstrating depraved indifference to human life. The court also held that County Court properly precluded psychiatric evidence concerning Bender's bipolar disorder because he failed to timely comply with CPL 250.10 and did not establish good cause for late notice.

Holdings

1. The evidence was legally sufficient for a rational jury to find that Bender consciously disregarded grave risks to human life and acted with depraved indifference while engaging in reckless driving.
2. County Court did not abuse its discretion by precluding Bender's psychiatric evidence concerning bipolar disorder because he failed to provide timely CPL 250.10 notice, did not establish good cause for the delay, and the late disclosure prejudiced the People.

Questions Presented

1. Whether the trial evidence was legally sufficient to establish depraved indifference to human life, an element of first-degree reckless endangerment.
2. Whether County Court abused its discretion by precluding psychiatric evidence concerning Bender's bipolar disorder because he failed to comply with CPL 250.10's notice requirement.
3. Whether preclusion of the psychiatric evidence deprived Bender of his constitutional right to present a defense.

Disposition

affirmed