People v. Welch

2026 NY Slip Op 00700
CourtAppellate Division of the Supreme Court of the State of New York
DecidedFebruary 11, 2026
Docket688 KA 23-01776
StatusPublished

This text of 2026 NY Slip Op 00700 (People v. Welch) is published on Counsel Stack Legal Research, covering Appellate Division of the Supreme Court of the State of New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Welch, 2026 NY Slip Op 00700 (N.Y. Ct. App. 2026).

Opinion

People v Welch (2026 NY Slip Op 00700)
People v Welch
2026 NY Slip Op 00700
Decided on February 11, 2026
Appellate Division, Fourth Department
Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431.
This opinion is uncorrected and subject to revision before publication in the Official Reports.


Decided on February 11, 2026 SUPREME COURT OF THE STATE OF NEW YORK Appellate Division, Fourth Judicial Department
PRESENT: LINDLEY, J.P., MONTOUR, OGDEN, GREENWOOD, AND HANNAH, JJ.

688 KA 23-01776

[*1]THE PEOPLE OF THE STATE OF NEW YORK, RESPONDENT,

v

AARON WELCH, DEFENDANT-APPELLANT.


CAMBARERI & BRENNECK, SYRACUSE (MELISSA K. SWARTZ OF COUNSEL), FOR DEFENDANT-APPELLANT.

TODD C. CARVILLE, DISTRICT ATTORNEY, UTICA (MICHAEL A. LABELLA OF COUNSEL), FOR RESPONDENT.



Appeal from an order of the Oneida County Court (Robert Bauer, J.), dated September 30, 2022. The order, inter alia, dismissed without prejudice the application of defendant for resentencing pursuant to CPL 440.47.

It is hereby ORDERED that the order so appealed from is affirmed.

Memorandum: Defendant appeals from an order that, inter alia, dismissed without prejudice his application for resentencing pursuant to the Domestic Violence Survivors Justice Act (DVSJA) (see CPL 440.47 [2] [d]). The DVSJA grants "courts discretion to impose less severe sentences on certain defendants who were victims of domestic violence at the time of their crimes" (People v Krista M.G., 228 AD3d 1300, 1301 [4th Dept 2024], lv denied 42 NY3d 1036 [2024]; see CPL 440.47; Penal Law § 60.12). Under CPL 440.47, a defendant who committed certain qualifying crimes prior to the effective date of the DVSJA and whose sentence meets certain requirements may seek resentencing in the court in which their sentence was imposed.

As relevant here, CPL 440.47 (2) (c) provides that an application for resentencing "must include at least two pieces of evidence corroborating the [defendant's] claim that he or she was, at the time of the offense, a victim of domestic violence subjected to substantial physical, sexual[,] or psychological abuse inflicted by a member of the same family or household as the [defendant] as such term is defined in [CPL 530.11 (1)]." Paragraph (d) of CPL 440.47 (2) mandates that a court "dismiss the application without prejudice" when it determines that the defendant has not complied with the provisions of paragraph (c) of section 440.47 (2).

Here, defendant pleaded guilty in 2014 to two counts of murder in the second degree (Penal Law § 125.25 [1]) and was sentenced to consecutive terms of 20 years to life in prison on each count. The first murder victim was defendant's ex-girlfriend, whom defendant stabbed 13 times in her head, face, and neck, among other places. The second murder victim was a man residing at the same apartment as the ex-girlfriend, who intervened in an attempt to help the ex-girlfriend when defendant was stabbing her. Neither victim was armed, and neither presented any threat to defendant, who was upset that his ex-girlfriend had ended their relationship and was seeing another man.

After serving approximately nine years of his sentence, defendant applied for resentencing pursuant to the DVSJA. In support of his application alleging that he was a victim of domestic violence, defendant submitted, among other things, an affidavit in which he claimed that various people, including the two victims, had subjected him to bullying and psychological and physical abuse for months prior to the murders. The People opposed the application, contending that defendant was not entitled to a hearing under CPL 440.47 (2) (e) because he failed to submit sufficient proof as required under subdivision (2) (c) to corroborate his claim that he was a victim of domestic violence when he committed the murders. County Court [*2]summarily "denied without prejudice" defendant's application after determining that he did not include "at least two pieces of evidence corroborating his claim that he was, at the time of the offense, a victim of domestic violence subjected to substantial physical, sexual[,] or psychological abuse inflicted by a member of the same family or household as himself as defined in CPL [ ]530.11 (1)."

As a preliminary matter, we agree with defendant that he may appeal from that part of the order dismissing his application for resentencing without prejudice. We conclude that the order constitutes "an order denying resentencing," from which an appeal may be taken as of right (CPL 440.47 [3] [a]). Although we recognize that the Third Department has held otherwise, interpreting the statutory phrase "an order denying resentencing" to mean an order denying resentencing after a hearing, rather than an order summarily dismissing an application for resentencing without prejudice (see People v Melissa OO., 234 AD3d 101, 103-106 [3d Dept 2024]; People v James QQ., 232 AD3d 1137, 1138 [3d Dept 2024], lv denied 43 NY3d 964 [2025]), we do not read the statute so restrictively. As a remedial statute, the DVSJA should be "liberally construed to carry out the reforms intended and to promote justice" (McKinney's Cons Laws of NY, Statutes § 321; see generally People v Brown, 25 NY3d 247, 251 [2015]). "A liberal construction . . . is one [that] is in the interest of those whose rights are to be protected, and if a case is within the beneficial intention of a remedial act it is deemed within the statute, though actually it is not within the letter of the law" (Matter of Dewine v State of N.Y. Bd. of Examiners of Sex Offenders, 89 AD3d 88, 92 [4th Dept 2011] [internal quotation marks omitted]; see McKinney's Cons Laws of NY, Statutes § 321, Comment).

As the Third Department recognized in Melissa OO. (234 AD3d at 106 n 5), its reading of CPL 440.47 (3) would insulate from judicial review orders that improperly dismiss applications that meet the evidentiary provisions of subdivision (2) (c), leaving defendants who are deserving of hearings with no legal recourse except to refile their applications, which could be improperly and repeatedly denied again. Such a narrow construction of CPL 440.47 is not compelled by the statutory language and is contrary to well established rules of construction for remedial statutes (see Brown, 25 NY3d at 251; Dewine, 89 AD3d at 92; see also People v Sosa, 18 NY3d 436, 440-441 [2012]). If the legislature intended to deprive defendants of the right to appeal from summary denials of applications for resentencing under the DVSJA, it should have "clearly expressed" such a limitation through unambiguous language in CPL 440.47 (3) (a) (Brown, 25 NY3d at 251 [internal quotation marks omitted]). Given that the legislature did not expressly exclude orders summarily dismissing applications for resentencing from the phrase "an order denying resentencing" under CPL 440.47 (3) (a), we will not read in that limitation inasmuch as it would be "at odds with the broad objectives of the remedial enactment" of the DVSJA (Sosa, 18 NY3d at 441).

Our statutory interpretation, i.e., that an order dismissing an application for resentencing for failure to comply with the evidentiary provisions under CPL 440.47 (2) (c) is tantamount to "an order denying resentencing" under CPL 440.47 (3) (a), is also supported by language in the statute providing that a defendant may request appointment of counsel "on any appeals

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Bluebook (online)
2026 NY Slip Op 00700, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-welch-nyappdiv-2026.