The People v. Gonzalo Aguilar

CourtNew York Court of Appeals
DecidedFebruary 20, 2024
Docket3
StatusPublished

This text of The People v. Gonzalo Aguilar (The People v. Gonzalo Aguilar) is published on Counsel Stack Legal Research, covering New York Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The People v. Gonzalo Aguilar, (N.Y. 2024).

Opinion

State of New York OPINION Court of Appeals This opinion is uncorrected and subject to revision before publication in the New York Reports.

No. 3 The People &c., Respondent, v. Gonzalo Aguilar, Appellant.

Jan Hoth, for appellant. Stephen J. Kress, for respondent.

SINGAS, J.:

Defendant claims that the trial court erred by failing to include a reinstruction on

the justification defense in its response to a jury note. We disagree and hold that the court’s

response was meaningful. Defendant’s additional argument that the court’s interested

-1- -2- No. 3

witness charge violated defendant’s constitutional right to due process is unpreserved for

our review.

I.

In 2000, defendant, his friend, and a group of patrons engaged in an altercation

outside a Manhattan bar. Defendant stabbed one victim three times in the chest with a

knife, killing him, and slashed another victim’s neck causing serious physical injury.

Defendant was charged with murder in the second degree, attempted murder in the second

degree, and assault in the first degree. During defendant’s 2002 trial, the court instructed

the jury on the elements of ten criminal offenses: the charged offenses, as well as several

lesser included offenses. Defendant asserted that he acted in self-defense and the court

accordingly instructed the jury on justification (see Penal Law § 35.15). Because defendant

testified, the court also instructed the jury that defendant was an interested witness and that

his interest in the outcome of the proceedings was one factor to consider in evaluating his

credibility. Prior to jury deliberations, the court told the jurors that if they had “any

questions on the law, please write me a note specifying the particular law you wish me to

review and I’ll bring you back into the courtroom and do that.”

On the first day of deliberations, the jury sent a note to the court requesting “[a]ll

definitions discussed: Murder II, Manslaughter I, Depraved Murder II, etc.,” as well as a

readback of certain testimony, among other things. The court communicated to the parties

that it intended to “give [the jury] the elements of all the crimes again before lunch” and

provide the relevant testimony after lunch. The court asked defense counsel if that plan

-2- -3- No. 3

was “acceptable” and counsel responded in the affirmative. The court then reread the

instructions for the charged counts but did not reinstruct the jury on justification. At the

conclusion of the recharge, the court stated, “I hope that answers your question concerning

the charges to the case” and informed the jury that the relevant testimony would be read

back after lunch. At that point, defense counsel requested that the court reinstruct the jury

on “the definition of justification,” which the court declined on the ground that the jury

“didn’t ask for that” but rather had “specified the counts.”

The jury convicted defendant of murder in the second degree, attempted murder in

the second degree, and assault in the first degree. The Appellate Division affirmed the

judgment, holding that the trial court responded meaningfully to the jury note “by rereading

its instructions on the elements of the offenses submitted to the jury, without mentioning

the defense of justification” because “[t]he jury did not ask for reinstruction on

justification” (206 AD3d 572, 573 [1st Dept 2022]). Further, as relevant here, the Court

concluded that defendant’s constitutional challenge to the interested witness charge was

unpreserved and, in the alternative, unavailing (id. at 573-574). A Judge of this Court

granted defendant leave to appeal (38 NY3d 1186 [2022]).

II.

“CPL 310.30 provides that the jury may request further instructions at any time

during its deliberations and if it does so the court must ‘give such requested information or

instruction as [it] deems proper’ ” (People v Almodovar, 62 NY2d 126, 131 [1984]).

Because “[t]he trial court is generally in the best position to evaluate the jury’s request”

-3- -4- No. 3

(People v Steinberg, 79 NY2d 673, 684 [1992]), trial courts are vested with “significant

discretion in determining the proper scope and nature of the response” (People v Taylor,

26 NY3d 217, 224 [2016]). But that discretion is cabined by the requirement that a court

“respond meaningfully to the jury’s inquiries” (Almodovar, 62 NY2d at 131).

“The factors to be evaluated” in determining whether a response to a jury note is

meaningful “are ‘the form of the jury’s question, which may have to be clarified before it

can be answered, the particular issue of which inquiry is made, the supplemental instruction

actually given and the presence or absence of prejudice to the defendant’ ” (id. at 132,

quoting People v Malloy, 55 NY2d 296, 302 [1982]). Failure to answer a jury’s note

meaningfully is an abuse of discretion as a matter of law (see Taylor, 26 NY3d at 224,

citing Malloy, 55 NY2d at 302).

In this case, “the form of the jury’s” note indicated a request that the jury be

recharged on the elements of the crimes (see Almodovar, 62 NY2d at 131 [internal

quotation marks omitted]). The jury note asked for “all definitions” contained in the

charges: the jury did not simply ask for “all definitions” to be read back but instead chose

to limit which “definitions” it sought by providing an exemplary list containing the first

three of the ten criminal offenses on which the trial court had originally instructed the jury

and ending the list with “etc.” The usage of “etc.” in this context corroborates this

interpretation of the note because et cetera at the end of a list signals “others especially of

the same kind” (Merriam-Webster.com Dictionary, et cetera [https://www.merriam-

webster.com/ dictionary/et%20cetera]). That the jury did not seek further instruction or

-4- -5- No. 3

clarification after the recharge also supports our conclusion that the trial court correctly

interpreted the jury note and responded meaningfully and with the complete information

sought (see Almodovar, 62 NY2d at 132; compare Malloy, 55 NY2d at 303 [jury’s silence

following the court’s response to its note was indicative of satisfaction with the response];

with Taylor, 26 NY3d at 227 [court’s response to a jury note was not meaningful despite

the jury’s decision to “cease their inquiry”]).

Additionally, upon conclusion of its response to the portion of the jury’s note

requesting recharge, defense counsel then requested that the court recharge justification.

Returning to that portion of the jury note at that time may have “placed undue emphasis on

the issue” (see id.).

Defendant’s remaining argument is unpreserved, as he concedes, and no exception

to the preservation rule applies under these circumstances (see People v Cabrera, — NY3d

—, 2023 NY Slip Op 05968 [2023]; see also People v Peque, 22 NY3d 168 [2013]).

Accordingly, the order of the Appellate Division should be affirmed.

-5- WILSON, Chief Judge (concurring):

I write separately to make clear what is decided and undecided on this appeal. Mr.

Aguilar’s appeal presents three distinct questions of law. First, Mr. Aguilar contends that

the jury’s note, which asked for “all definitions,” required the court to recharge the jury the

instruction on justification. I agree with the Court’s rejection of that argument.

Second, Mr.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

The People v. Rhian Taylor
43 N.E.3d 350 (New York Court of Appeals, 2015)
People v. Peque
3 N.E.3d 617 (New York Court of Appeals, 2013)
People v. Malloy
434 N.E.2d 237 (New York Court of Appeals, 1982)
People v. Almodovar
464 N.E.2d 463 (New York Court of Appeals, 1984)
People v. Steinberg
595 N.E.2d 845 (New York Court of Appeals, 1992)

Cite This Page — Counsel Stack

Bluebook (online)
The People v. Gonzalo Aguilar, Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-people-v-gonzalo-aguilar-ny-2024.