From Casetext: Smarter Legal Research

People v. Cotton

Appellate Division of the Supreme Court of New York, Second Department
Sep 22, 1997
242 A.D.2d 638 (N.Y. App. Div. 1997)

Summary

finding that a new trial was needed because the prosecutor “advanced a theory premised on a fact that he knew to be false.”

Summary of this case from Dawson v. The City of New York

Opinion

September 22, 1997

Appeal from the Supreme Court, Kings County (J. Goldberg, J.).


Ordered that the judgment is reversed, as a matter of discretion in the interest of justice, and a new trial is ordered.

The hearing court properly declined to suppress the gun recovered as a result of the arresting officer's inquiry concerning its location. The officer's inquiry was justifiable for safety reasons and did not violate the defendant's constitutional right against self-incrimination ( see, New York v Quarles, 467 U.S. 649, 658-669; see also, People v. Palumbo, 209 A.D.2d 551).

While the prosecutor's attack on the defendant's justification defense during summation was not objected to at trial, we nevertheless feel compelled, under the circumstances of this case, to reach the issue in the exercise of our interest of justice jurisdiction and to reverse ( see, People v. Jackson, 143 A.D.2d 363).

As the Court of Appeals noted in People v. Pelchat ( 62 N.Y.2d 97, 105), the prosecutor "is charged with the duty not only to seek convictions but also to see that justice is done" and "owes a duty of fair dealing to the accused and candor to the courts". The interest of justice is disserved when, as here, a prosecutor during summation advances a theory premised on a fact that he knows to be false in order to discredit the defendant's justification defense ( see, People v. Lantigua, 228 A.D.2d 213). It is undisputed that the prosecutor knew that the .32 caliber gun, which the defense contended the decedent aimed at the defendant, was inoperable. Yet, in attacking the defendant's justification defense, the prosecutor argued on summation that if the decedent had drawn a gun as the defendant contended, the defendant would not have had time to turn around, take two or three steps, receive a gun from someone in the crowd, turn back and fire four bullets before the decedent was able to fire a single shot. This blatant misrepresentation of the facts as known to the prosecutor went to the heart of the defendant's justification defense, a defense which the prosecutor was obligated to disprove beyond a reasonable doubt. Reversal is required because the prosecutor's misconduct in summation may very well have tipped the scales against the defendant, especially in light of the less than overwhelming evidence of the defendant's guilt ( see, People v. Tolbert, 198 A.D.2d 132; People v Nieves, 186 A.D.2d 276). Because the prosecutor's misconduct was flagrant and closely related to the credibility issue presented at trial, the defendant's case was substantially prejudiced ( see generally, People v. Elder, 207 A.D.2d 498; People v. Dombrowski, 163 A.D.2d 873).

The defendant's remaining contentions are either without merit or are rendered academic in light of our determination.

Rosenblatt, J.P., Thompson, Pizzuto and Altman, JJ., concur.


Summaries of

People v. Cotton

Appellate Division of the Supreme Court of New York, Second Department
Sep 22, 1997
242 A.D.2d 638 (N.Y. App. Div. 1997)

finding that a new trial was needed because the prosecutor “advanced a theory premised on a fact that he knew to be false.”

Summary of this case from Dawson v. The City of New York

In People v Cotton, 242 AD2d 638, 639, (2d Dept. 1997), the defendant's conviction for manslaughter was reversed in the interest of justice due to the prosecutor's "blatant misrepresentation of the facts as known to the prosecutor."

Summary of this case from People v. Canales

In People v Cotton, 242 AD2d 638, 639, (2d Dept. 1997), the defendant's conviction for manslaughter was reversed in the interest of justice due to the prosecutor's "blatant misrepresentation of the facts as known to the prosecutor."

Summary of this case from People v. Canales
Case details for

People v. Cotton

Case Details

Full title:THE PEOPLE OF THE STATE OF NEW YORK, Respondent, v. ANDRE COTTON, Appellant

Court:Appellate Division of the Supreme Court of New York, Second Department

Date published: Sep 22, 1997

Citations

242 A.D.2d 638 (N.Y. App. Div. 1997)
662 N.Y.S.2d 135

Citing Cases

People v. Gregory Spann

The prosecutor also impermissibly shifted the burden of proof to the defendant by informing the jurors that…

People v. Walters

He persisted with this implication despite his knowledge that the ballistics test performed by police…