People v. Haggerty

Summary

The New York Court of Appeals affirmed John Haggerty’s convictions for grand larceny and money laundering arising from a scheme to defraud Michael R. Bloomberg of funds intended for a 2009 election-day ballot security operation. The court held that any error concerning testimony about the ownership of funds held in Bloomberg’s revocable trust was harmless, particularly because other witnesses and documentary evidence established Bloomberg’s ownership. The court also concluded that the best evidence rule challenge was unavailing in light of the other ownership evidence admitted without objection.

Holdings

1. The best-evidence challenge did not warrant reversal because Haggerty allowed other evidence of Bloomberg's ownership to be admitted without objection, and the challenged testimony was not sufficiently prejudicial to deny him a fair trial.
2. The challenge was of no moment because defendant raised his objection only after Bloomberg and other prosecution witnesses had already testified to facts tending to establish ownership.

Questions Presented

1. Whether testimony concerning Bloomberg's ownership of funds held in the Michael R. Bloomberg Revocable Trust violated the best evidence rule because the trust instrument was not introduced.
2. Whether any error in admitting the trust draftsperson's testimony required reversal of Haggerty's convictions.

Disposition

affirmed