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People v. LaPlanche

Appellate Division of the Supreme Court of New York, Fourth Department
May 28, 1993
193 A.D.2d 1062 (N.Y. App. Div. 1993)

Opinion

May 28, 1993

Appeal from the Niagara County Court, Hannigan, J.

Present — Callahan, J.P., Green, Lawton, Doerr and Boehm, JJ.


Judgment unanimously reversed as a matter of discretion in the interest of justice and new trial granted. Memorandum: The evidence, viewed in the light most favorable to the People (see, People v Contes, 60 N.Y.2d 620), was sufficient to support the conviction and the verdict was not contrary to the weight of the evidence (see, People v Bleakley, 69 N.Y.2d 490, 495).

However, County Court's instructions to the jury on reasonable doubt unconstitutionally diminished the People's burden of proof and deprived defendant of a fair trial (see, People v Banks, 193 A.D.2d 1051 [decided herewith]; People v Freeman, 193 A.D.2d 1117 [decided herewith]; People v Payne, 192 A.D.2d 1117; People v Frank, 186 A.D.2d 977).

Since a new trial is necessary, we note that, on the evidence in this record, the court erred in denying defendant's request for a circumstantial evidence charge (see, People v Silva, 69 N.Y.2d 858, 859; People v Ford, 66 N.Y.2d 428; People v Sanchez, 61 N.Y.2d 1022).

The court properly permitted defendant's wife to testify concerning the time her husband arrived home on the morning of May 14, 1987, as well as her discovery of a duffel bag and its contents later that day, because those observations were not "'communications'" protected by the marital privilege (People v Wilson, 64 N.Y.2d 634, 636). With respect to the other "communications" that took place over a period of approximately six months to a year, we conclude that, although those communications were presumably privileged when made (see, CPLR 4502 [b]), the privilege was lost because the substance of those communications was revealed to a third party (see, Matter of Vanderbilt [Rosner — Hickey], 57 N.Y.2d 66, 74).


Summaries of

People v. LaPlanche

Appellate Division of the Supreme Court of New York, Fourth Department
May 28, 1993
193 A.D.2d 1062 (N.Y. App. Div. 1993)
Case details for

People v. LaPlanche

Case Details

Full title:THE PEOPLE OF THE STATE OF NEW YORK, Respondent, v. ADRIAN P. LaPLANCHE…

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

Date published: May 28, 1993

Citations

193 A.D.2d 1062 (N.Y. App. Div. 1993)
598 N.Y.S.2d 877

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