People v. Felder

8 Misc. 3d 528, 794 N.Y.S.2d 619, 2005 NY Slip Op 25163, 2005 N.Y. Misc. LEXIS 857
CourtNew York County Courts
DecidedFebruary 17, 2005
StatusPublished

This text of 8 Misc. 3d 528 (People v. Felder) is published on Counsel Stack Legal Research, covering New York County Courts primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Felder, 8 Misc. 3d 528, 794 N.Y.S.2d 619, 2005 NY Slip Op 25163, 2005 N.Y. Misc. LEXIS 857 (N.Y. Super. Ct. 2005).

Opinion

[529]*529OPINION OF THE COURT

C. Randall Hinkichs, J.

The instant indictment charges all three codefendants with murder in the second degree, in violation of Penal Law § 125.25 (3) under a felony murder theory of causing the death of a nonparticipant during the course of or immediate flight from a robbery. In addition, Anthony Ryans is also charged alone with a single count of murder in the first degree, in violation of Penal Law § 125.27 (1) (a) (vii) as the People allege that he actually fired the weapon which resulted in the death of a nonparticipant during the course of or immediate flight from the robbery.

On January 27, 2005, all three defendants made oral applications for severance of their case from each of the codefendants. All three stated the grounds for severance to be Bruton considerations, in that all three codefendants gave statements implicating the other two participants to varying degrees. All three also asserted that severance was required based on inconsistent or antagonistic defenses which would be proffered at trial.

In response, the People unequivocally represented that they would not be willing to proceed to trial without the defendants’ statements and that there was no way to effectively redact the statements so as to proceed with a single trial of all three defendants. The People cross-moved, however, for partial severance by way of a dual jury trial for defendants Anthony Ryans and Gregory Felder, based on the large volume of evidence in common to both defendants.

The court ruled that severance, in some manner, would be granted and heard oral argument on the People’s application for a dual jury trial as to Anthony Ryans and Gregory Felder. The People represented that their application to try Ryans and Felder before dual juries, as opposed to either Ryans and Kelley or Felder and Kelley, is based on their position that Ryans, as charged in the indictment, fired the shot which resulted in the death, and that Felder is the “mastermind” of the alleged robbery/murder. Inasmuch as the People’s application pertained to defendants Ryans and Felder, counsel for defendant Kelley took no position on the application.

The People, in support of their application for a dual jury trial for Ryans and Felder, submit that all three defendants are [530]*530charged with acting in concert as to the felony murder, so the dual jury trial would involve the same theory and the same criminal transaction (with Ryans having the additional count of murder in the first degree). The People point out that there are 24 witnesses in common to Ryans and Felder, including a civilian eyewitness who should not have to testify in three separate trials. The only witnesses who are not common to Ryans and Felder are the two different police detectives who took the written statements from Ryans and Felder, respectively. The People submit that “if proof against codefendants is supplied by the same evidence only the most cogent reasons warrant a severance.” (People v Ricardo B., 73 NY2d 228, 233 [1989], citing People v Bomholdt, 33 NY2d 75, 87 [1973].)

The People submit that they will be prejudiced if they are required to conduct three separate trials. The People direct the court’s attention to People v Ricardo B. (73 NY2d 228 [1989]) and People v Singh (266 AD2d 569 [2d Dept 1999]), among others, as providing support for the use of dual juries under similar circumstances. The People submit that, in light of all of the circumstances of the instant case, particularly the number of witnesses in common, judicial economy dictates that a dual jury trial be ordered for defendants Ryans and Felder.

Defendant Ryans, through counsel, opposes the application for a dual jury trial. Ryans concedes that judicial economy and witnesses in common are appropriate considerations; however, he urges such considerations cannot take precedence over the potential for prejudice to the defendant. Ryans submits that he will be prejudiced by the fact that counsel for Felder will attempt to elicit, through cross-examination, damaging evidence against Ryans. Ryans submits that he will, in effect, have to defend against two prosecutors, the Assistant District Attorney and counsel for Felder. Separate trials are, therefore, according to Ryans, required because of antagonistic defenses between Ry-ans and Felder.

Felder, through counsel, also contends that Ryans and Felder have antagonistic defenses. Counsel for Felder requested, in support of his application in opposition to a dual jury trial with Ryans, an in camera conference with the court. Felder urged, in this regard, that he should be permitted to explain his defense to the court in camera without revealing his defense strategy to the People in open court. This procedure, he argued, would permit the court to decide whether the defenses of Felder and Ryans were sufficiently antagonistic so as to warrant separate [531]*531trials without requiring him to reveal his defense strategy to the People. The People opposed this request for an in camera offer by counsel for Felder. The court permitted counsel for Felder to make an in camera offer as to his proposed defense at trial, citing People v Burrows (280 AD2d 132 [4th Dept 2001]) and People v Hall (179 Misc 2d 488 [Sup Ct, Monroe County 1998]) by analogy only, since those cases clearly apply to requests for severance by a single defendant of various unrelated counts in an indictment, and not, as here, multiple defendants. Prior to conducting the in camera proffer in chambers, Mr. Felder voluntarily waived, on the record, his own personal appearance in chambers and permitted his counsel to act on his behalf for this limited purpose. The in camera offer by counsel for Felder was taken down by the court reporter for the record. The minutes of this in camera offer shall be sealed and shall remain in the court file in the event of the need for future appellate review.

While the court will not reveal the intended defense outlined by counsel in camera, counsel for Felder acknowledged, on the record in open court in the presence of all defendants and counsel and the prosecutor, that his defense would involve highlighting Ryans’ involvement in the instant offense, through his (counsel for Felder) cross-examination of the witnesses.

The leading case on the use of dual juries, as cited by both sides, is People v Ricardo B. (73 NY2d 228 [1989]). The Court of Appeals in Ricardo B. specifically authorized the practice of dual juries as a form of “partial severance” in cases where a large volume of the evidence is common to all defendants. The Court in Ricardo B. warns, however, that “[m]ultiple juries are to be used sparingly and then only after a full consideration of the impact the procedure will have on the defendants’ due process rights and after thorough precautions have been taken to protect those rights.” (Id. at 235.)

In the instant case, the court finds that a dual jury trial of Ryans and Felder is required as an appropriate exercise of judicial economy and, with precautions outlined below, the due process rights of each defendant will be carefully protected.

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Related

People v. Bornholdt
305 N.E.2d 461 (New York Court of Appeals, 1973)
People v. Ricardo B.
535 N.E.2d 1336 (New York Court of Appeals, 1989)
People v. Mahboubian
543 N.E.2d 34 (New York Court of Appeals, 1989)
People v. Martin
154 A.D.2d 554 (Appellate Division of the Supreme Court of New York, 1989)
People v. Singh
266 A.D.2d 569 (Appellate Division of the Supreme Court of New York, 1999)
People v. Burrows
280 A.D.2d 132 (Appellate Division of the Supreme Court of New York, 2001)
People v. Hall
179 Misc. 2d 488 (New York Supreme Court, 1998)

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Bluebook (online)
8 Misc. 3d 528, 794 N.Y.S.2d 619, 2005 NY Slip Op 25163, 2005 N.Y. Misc. LEXIS 857, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-felder-nycountyct-2005.