The People v. Jason Bohn

CourtNew York Court of Appeals
DecidedMarch 19, 2024
Docket22
StatusPublished

This text of The People v. Jason Bohn (The People v. Jason Bohn) 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. Jason Bohn, (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. 22 The People &c., Respondent, v. Jason Bohn, Appellant.

Mark W. Vorkink, for appellant. Christopher Blira-Koessler, for respondent.

GARCIA, J.:

A jury convicted defendant of first-degree murder for killing a woman with whom

he had an extremely abusive relationship. Defendant claims the evidence was legally

insufficient to establish that he relished or took pleasure in the infliction of extreme -1- -2- No. 22

physical pain upon the victim so as to constitute “torture” under the first-degree murder

statute. We disagree and affirm.

A verdict will be considered “legally sufficient when, viewing the facts in a light

most favorable to the People, there is a valid line of reasoning and permissible inferences

from which a rational jury could have found the elements of the crime proved beyond a

reasonable doubt” (People v Danielson, 9 NY3d 342, 349 [2007] [internal quotation marks

and citations omitted]). Applying this standard, we conclude that there was sufficient proof

for a rational jury to determine that defendant relished or took pleasure in the infliction of

extreme pain.

A person who commits intentional murder “in the context of one or more of 13

aggravating factors” is guilty of first-degree murder (see People v Cahill, 2 NY3d 14, 57

[2003]; see also Penal Law § 125.27 [1]). Torture, the aggravating factor at issue here,

requires that the defendant “[w]ith intent to cause the death of another person, [] causes the

death of such person or of a third person; and . . . the defendant acted in an especially cruel

and wanton manner pursuant to a course of conduct intended to inflict and inflicting torture

upon the victim prior to the victim’s death” (Penal Law § 125.27 [1] [a] [x]). The statute

“requires a specific intent to inflict torture” (William C. Donnino, Practice Commentaries,

Penal Law § 125.27 [1] [a] [x]), which is defined as “the intentional and depraved infliction

of extreme physical pain” (Penal Law § 125.27 [1] [a] [x]). To establish depravity, the

evidence must demonstrate that “the defendant relished the infliction of extreme physical

pain upon the victim evidencing debasement or perversion or that the defendant evidenced

a sense of pleasure in the infliction of extreme physical pain” (id.). It is proof of this last

-2- -3- No. 22

element—that the defendant relished or took pleasure in inflicting extreme pain upon the

victim—that defendant argues was insufficient.

The Penal Law does not define the terms “relish” or “pleasure.” Black’s Law

Dictionary defines “pleasure” as “an agreeable sensation,” “mental gratification,” or

“something that one desires or chooses” (Black’s Law Dictionary [11th ed 2019]).

“Relish” is similarly defined as “a strong liking,” or “enjoyment of or delight in something

that satisfies one’s tastes, inclinations, or desires” (Merriam-Webster Online Dictionary,

relish [http://www.merriam-webster.com/dictionary/relish]). With those dictionary

definitions serving as “useful guideposts” (People v Ocasio, 28 NY3d 178, 181 [2016]

[internal quotation marks and citations omitted]), we turn to the record here.

The People’s proof with respect to this element of the crime fell into three general

categories: defendant’s threats and other abusive conduct toward the victim in the period

before the murder; the events that took place that night, including a voicemail that

inadvertently recorded the crime; and the medical examiner’s testimony about the nature

and extent of the victim’s injuries. This evidence, particularly the audio recording of a

portion of the attack during which the jury could hear the victim being repeatedly choked

and taunted by defendant and the medical testimony about the pain these injuries would

have caused, was sufficient to allow a rational jury to conclude beyond a reasonable doubt

that defendant relished or took pleasure in the infliction of extreme pain upon the victim.

Evidence in the first category established that several weeks before her death, the

victim reported defendant to the police. She arrived at the precinct limping, with large

bruises on her body and “visible red marks on her face.” She showed officers graphic and

-3- -4- No. 22

threatening emails sent by defendant earlier that day in which defendant described in detail

the ways he would sexually assault her as a “penalty” for lying and warned her that if she

did not obey him, he would “respond with a fury that satan himself would envy.” While

the victim was at the precinct, defendant called her, and the officers listened in as defendant

threatened to “dedicate [his] life to hunting [her] down like a dog on the street.”

The jury also heard evidence of defendant’s actions on the night of the murder,

including a nearly three-minute-long audio recording of defendant repeatedly strangling

the victim. That night, less than three weeks after she went to the precinct, the victim called

911. A recording of that emergency call was played for the jury. Although she is unable

to speak to the operator, the victim can be heard begging defendant to let her out of the

apartment and screaming in pain. Almost one hour later, the victim’s phone dialed a

friend’s telephone number and the call went to voicemail. On that recording, which

demonstrates that the attack was still ongoing, defendant is heard mocking the victim and

telling her that she did not “have a lot of time” left. He repeatedly asked her why she called

a certain number and told her that her responses were “probably good enough” and that he

“believe[d]” her. He nevertheless continued to attack her. As defendant demanded that

the victim “listen” to him, she told him that she was “choking,” and that she could no longer

breathe. Defendant asked her, “how does it feel?” Though still choking, the victim

managed to tell defendant that she loved him and that she could not breathe while begging

for help. Defendant can be heard telling her she had “five seconds” before he killed her

and that this was her “fault.” Towards the end of the recording, defendant told the victim

once more that she had “five seconds” and that he would “let” her get up to provide a

-4- -5- No. 22

sufficient answer “or else you die.” She is again heard screaming and choking. At that

point, her voice trails off and her responses become unintelligible before the call ends. Two

days later, police discovered the victim’s badly bruised body in her bathtub.

The medical examiner who performed the autopsy testified that the victim’s cause

of death was blunt force trauma to her torso and compression of her neck, each “potentially

a set of fatal injuries.” Many of her ribs and her sternum were fractured in a manner

consistent with being “stomped” with “a significant amount of force” and were likely

caused by “multiple impacts” to the front, back, and side of her body. Those fractures

caused contusions to her lungs and lacerations to her liver, which in turn caused her to

bleed internally, resulting in a loss of “nearly one third her total blood circulating volume.”

The testimony also showed that defendant used his hands to fatally strangle the victim with

such force that he fractured the cartilage in her upper trachea and caused deep

hemorrhaging in various muscles in her neck.

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Related

People v. Danielson
880 N.E.2d 1 (New York Court of Appeals, 2007)
People v. Cahill
809 N.E.2d 561 (New York Court of Appeals, 2003)
The People v. Alexis Ocasio
65 N.E.3d 1263 (New York Court of Appeals, 2016)

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