People v. Alyakoub

119 Misc. 2d 470, 463 N.Y.S.2d 380, 1983 N.Y. Misc. LEXIS 3539
CourtNew York Supreme Court
DecidedMay 25, 1983
StatusPublished

This text of 119 Misc. 2d 470 (People v. Alyakoub) is published on Counsel Stack Legal Research, covering New York Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Alyakoub, 119 Misc. 2d 470, 463 N.Y.S.2d 380, 1983 N.Y. Misc. LEXIS 3539 (N.Y. Super. Ct. 1983).

Opinion

OPINION OF THE COURT

Cornelius J. O’Brien, J.

The defendant, Justice Alyakoub, a native of Ghana, Africa, and a resident of Philadelphia where he is a college student, was apprehended at Kennedy Airport on December 18, 1982 as he came through customs with more than 10 pounds of marihuana after a visit to his homeland. He was subsequently indicted for criminal possession of marihuana in the first degree (Penal Law, § 221.30), a class C felony.

On March 23, 1983, it was agreed between the defense attorney and the prosecutor that if the defendant pleaded guilty to the indictment, the prosecutor would recommend to the court that the defendant be sentenced to a “split” sentence of five years’ probation with six months’jail time. (Penal Law, § 60.01, subd 2, par [d].) After a conference, the court agreed to the plea bargain and the defendant pleaded guilty.

[471]*471Before sentencing, it was determined that the provisions of subdivision 4 of section 70.00 of the Penal Law ostensibly do not apply to marihuana cases and that if a prison term was to be imposed on this defendant, its minimum would have to be at least one year as mandated by the other subdivisions of section 70.00.

On April 21, 1983, the defendant was sentenced in accordance with the plea bargain to five years’ probation, six months of which was to be served in prison. Not to fulfill the plea bargain would, in this court’s judgment, be violative of the equal protection clause of the Fourteenth Amendment to the United States Constitution.

Subdivision 4 of section 70.00 of the Penal Law reads as follows: “Alternative definite sentence for class D, E, and certain class C felonies. When a person, other than a second or persistent felony offender, is sentenced for a class D or class E felony, or to a class C felony specified in article two hundred twenty, and the court, having regard to the nature and circumstances of the crime and to the history and character of the defendant, is of the opinion that a sentence of imprisonment is necessary but that it would be unduly harsh to impose an indeterminate sentence, the court may impose a definite sentence of imprisonment and fix a term of one year or less.”

In 1976 when this statute was amended (L 1976, ch 480) to include class C felonies specified in article 220 of the Penal Law, marihuana offenses were included thereunder. Possession of one or more “preparations”, etc., of more than one ounce or of 100 or more cigarettes containing marihuana was a class C felony under former subdivisions 10 and 11 of section 220.09 of the Penal Law.

In 1977 (L 1977, ch 360), the Legislature passed the “Marihuana Reform Act”, the purpose being, according to the bill (§ 1), “to insure that the many people in New York who commit the conduct which this act makes a violation not be subject to unduly harsh sanctions.” Although marihuana continued to be defined under subdivision 6 of section 220.00 of the Penal Law,1 all offenses involving marihuana were now grouped under the new article 221 of [472]*472the Penal Law. However, this article did not apply to other forms of cannabis. The possession and sale of concentrated cannabis, commonly known as “hashish”, a more dangerous and pernicious drug2 continued to be proscribed by article 220.

As a result of what would appear to be a legislative oversight therefore, the law as it stands today would allow a person who is guilty of possession' of any amount of “concentrated cannabis” over an ounce (and it could be, for the sake of argument, 100 pounds) in violation of subdivision 10 of section 220.09 of the Penal Law to be sentenced to as little as one day in prison pursuant to subdivision 4 of section 70.00 of the Penal Law on a showing of undue harshness. On the other hand, a person such as the defendant here, convicted under the provisions of the so-called “Marihuana Reform Act” would have to serve at least a year.

The question before the court therefore is whether the incongruity which mandates a more severe punishment for this defendant than would be imposed on a similarly situated person in possession of the same drug in concentrated form, in conceivably a larger amount, renders subdivision 4 of section 70.00 of the Penal Law unconstitutional as violative of the Fourteenth Amendment to the United States Constitution.

As stated by Judge Gabrielli in Alevy v Downstate Med. Center of State of N. Y. (39 NY2d 326, 332):

“Traditional equal protection analysis is two tiered. Most classifications are subject to the lax standard of rationality which tests whether the challenged classification bears a reasonable relationship to some legitimate objective * * *

“Where, however, a statute affects a ‘fundamental interest’ or employs a ‘suspect’ classification, the strict scrutiny test has been applied.”

Judge Wachtler, in People v Whidden (51 NY2d 457, 460), states the law a little differently, as follows:

[473]*473“In evaluating whether a statute violates the equal protection clause a court normally applies a ‘rational basis’ test to determine whether the varied treatment of separate classifications of citizens ‘rests on grounds wholly irrelevant to the achievement of the State’s objective’ (McGowan v Maryland, 366 US 420, 425). Where a statute’s application differentiates on the basis of race, alienage or nationality, however, the classification is deemed suspect and a strict scrutiny test must be applied to determine whether the challenged law is ‘necessary to promote a compelling governmental interest’ (Shapiro v Thompson, 394 US 618, 634).

“Between those two tests, a third has developed to evaluate a constitutional challenge to a gender-based statute which ‘must serve important governmental objectives and must be substantially related to achievement of those objectives’ (Craig v Boren, 429 US 190, 197; see Califano v Webster, 430 US 313, 316-317).”

Chief Judge Cooke in Matter of Quinton A. (49 NY2d 328, 337) says that strict scrutiny is the proper test “only where the challenged law classifies persons along suspect lines, e.g., race, or where it impinges upon some fundamental constitutional right such as liberty”. However, where, as here, “only the extent and duration” of the deprivation of liberty are at issue, the rational basis test is to be applied.

In Matter of Malpica-Orsini (36 NY2d 568, 571) the Chief Judge stated: “Under traditional analysis, the equal protection clause does not deny to States the power to treat different classes of persons in different ways, but a classification must be reasonable, not arbitrary, and have a fair and substantial relation to the object of the legislation, so that all persons similarly circumstanced shall be treated alike (Reed v Reed, 404 US 71, 75-76; Neale v Hayduk, 35 NY2d 182, 186).”

Thus in Quinton (supra, p 337), the inquiry was “whether it was rational for the Legislature to have afforded juveniles who commit crimes of violence against the elderly treatment disparate from those who perpetrate crime against the general populace”. And in People v [474]*474Parker (41 NY2d 21, 25) it was said that the rational basis test demands that “a legislative classification be rationally related to a legitimate State purpose”.

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Related

McGowan v. Maryland
366 U.S. 420 (Supreme Court, 1961)
Levy v. Louisiana Ex Rel. Charity Hospital
391 U.S. 68 (Supreme Court, 1968)
Shapiro v. Thompson
394 U.S. 618 (Supreme Court, 1969)
Reed v. Reed
404 U.S. 71 (Supreme Court, 1971)
Frontiero v. Richardson
411 U.S. 677 (Supreme Court, 1973)
Weinberger v. Wiesenfeld
420 U.S. 636 (Supreme Court, 1975)
Craig v. Boren
429 U.S. 190 (Supreme Court, 1976)
Califano v. Goldfarb
430 U.S. 199 (Supreme Court, 1977)
Califano v. Webster
430 U.S. 313 (Supreme Court, 1977)
Orr v. Orr
440 U.S. 268 (Supreme Court, 1979)
Am Knitwear v. Exp.-Imp.
41 N.Y.2d 14 (New York Court of Appeals, 1976)
Neale v. Hayduk
316 N.E.2d 861 (New York Court of Appeals, 1974)
In re the Adoption of Malpica-Orsini
331 N.E.2d 486 (New York Court of Appeals, 1975)
Alevy v. Downstate Medical Center
348 N.E.2d 537 (New York Court of Appeals, 1976)
In re Quinton A.
402 N.E.2d 126 (New York Court of Appeals, 1980)
People v. Whidden
415 N.E.2d 927 (New York Court of Appeals, 1980)
Claim of Passante v. Walden Printing Co.
53 A.D.2d 8 (Appellate Division of the Supreme Court of New York, 1976)
Childs v. Childs
69 A.D.2d 406 (Appellate Division of the Supreme Court of New York, 1979)
Greschler v. Greschler
71 A.D.2d 322 (Appellate Division of the Supreme Court of New York, 1979)

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Bluebook (online)
119 Misc. 2d 470, 463 N.Y.S.2d 380, 1983 N.Y. Misc. LEXIS 3539, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-alyakoub-nysupct-1983.