People v. Williams

Summary

The Appellate Division, First Department, unanimously affirmed Glenn Williams's convictions for first-degree robbery, first-degree strangulation, and second-degree assault, and his aggregate 20-year sentence. The court held that challenges to the trial court's responses to jury notes were unpreserved and, alternatively, that the responses were meaningful; it also rejected claims concerning jury-note disclosure and alleged instructional error.

Holdings

1. Defendant's challenges to the trial court's responses to the jury notes were unpreserved because defense counsel agreed with the proposed responses and did not except to the supplemental instructions as given; the court declined to review the claims in the interest of justice.
2. The trial court provided meaningful responses to the jury's notes by rereading the relevant charges and definitions, explaining the governing legal standards, and directing the jury to apply those standards to the facts of the case without directing how the facts should be evaluated.
3. The court rejected defendant's argument that the trial court should have corrected an alleged jury misapprehension concerning whether first-degree strangulation required an intent to cause serious physical injury and whether serious physical injury had to result; the claim was improperly raised for the first time in the reply brief, and any error was harmless in any event.
4. The trial court did not commit a mode-of-proceedings error because the record showed that defense counsel read the jury note before the court read it into the record.

Questions Presented

1. Whether defendant preserved his challenges to the trial court's responses to the jury notes.
2. Whether the trial court provided meaningful responses to the jury's requests for rereading and clarification of the charges.
3. Whether the trial court was required to correct an alleged jury misapprehension concerning the intent and serious-physical-injury elements of first-degree strangulation.
4. Whether the alleged instructional error was harmless.
5. Whether the trial court committed a mode-of-proceedings error by failing to convey the full contents of a jury note to defense counsel.

Disposition

affirmed