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People v. Sandoval

Appellate Division of the Supreme Court of New York, First Department
Dec 14, 1982
91 A.D.2d 536 (N.Y. App. Div. 1982)

Opinion

December 14, 1982


Judgment, Supreme Court, Bronx County (Warner, J.), rendered on December 10, 1980, unanimously affirmed.

Concur — Ross, J.P., Carro and Bloom, JJ.


I concur in the result, but I take this opportunity to express my views pertaining to the inappropriate use of the expression "to a moral certainty" in instructing a jury. I object to its use whether or not such phrase is appended to the words "beyond a reasonable doubt" or if used in connection with the pattern charge given for the evaluation of circumstantial evidence. Judge Fuchsberg recently took cognizance of the inherent difficulties encountered when a Trial Judge instructs a jury in language containing the phrase "`to a moral certainty'" ( People v Gonzalez, 54 N.Y.2d 729, 730). One of the principal responsibilities of a Trial Justice is to ensure that the jury fully comprehends the charge. Some Trial Judges have declined requests to use the term in defining "`reasonable doubt'", concluding that, while the phrase "`to a moral certainty'" might be synonymous with the term "`beyond a reasonable doubt'", its use was "likely to mislead the jury as to the degree of proof necessary to convict". ( People v Hicks, 91 Misc.2d 205, 208, affd 70 A.D.2d 1061.) "To a moral certainty" is not a constructive addition to any charge and, conceivably in some situations, may lead to error. At best, these words in the context of a criminal trial are confusing and should be eliminated from the lexicon of the Judge in charging a jury on any aspect of the proof. However, in light of the overwhelming proof of defendant's guilt, the use of the phrase here was harmless ( People v Crimmins, 36 N.Y.2d 230).


Summaries of

People v. Sandoval

Appellate Division of the Supreme Court of New York, First Department
Dec 14, 1982
91 A.D.2d 536 (N.Y. App. Div. 1982)
Case details for

People v. Sandoval

Case Details

Full title:THE PEOPLE OF THE STATE OF NEW YORK, Respondent, v. ROY SANDOVAL, Appellant

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

Date published: Dec 14, 1982

Citations

91 A.D.2d 536 (N.Y. App. Div. 1982)

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