The People v. Jose M. Rivera

CourtNew York Court of Appeals
DecidedNovember 21, 2023
Docket64
StatusPublished

This text of The People v. Jose M. Rivera (The People v. Jose M. Rivera) 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. Jose M. Rivera, (N.Y. 2023).

Opinion

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

No. 64 The People &c., Respondent, v. Jose M. Rivera, Appellant.

Guy Talia, for appellant. Lisa Gray, for respondent. Hon. Letitia James, New York State Attorney General, intervenor.

MEMORANDUM:

The order of the Appellate Division should be affirmed.

Defendant Jose M. Rivera argues that the sentencing court failed to exercise its

discretion pursuant to Criminal Procedure Law § 720.10 to determine whether qualifying

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mitigating circumstances existed that would make him eligible for youthful offender

adjudication. We hold that the court did exercise its discretion in making the required

eligibility determination. Defendant also advances, for the first time in this Court, several

arguments for youthful offender eligibility based on New York State Rifle & Pistol Assn.,

Inc. v Bruen, 142 S Ct 2111 (2022). These arguments are unpreserved, and for the reasons

set forth in People v Cabrera (decided today), we do not reach them.

The conviction underlying defendant’s sentence stems from his display of a loaded

gun during an argument over a parking space in 2010, when he was 17 years old.

Defendant pleaded guilty to criminal possession of a weapon in the second degree and was

sentenced as a second felony offender based on a 2007 felony conviction, which rendered

him ineligible for youthful offender treatment (see CPL 720.10 [2] [b]). The 2007 felony

conviction was vacated in 2016, leaving no predicate felony to support his 2011 second

felony offender sentence. The 2011 sentence was accordingly vacated, and defendant was

scheduled for resentencing.

At resentencing, defendant was no longer precluded from arguing eligibility for

youthful offender treatment (see CPL 720.10 [2]), but the court denied his application upon

finding that he was not an eligible youth. The court first acknowledged that CPL 720.10

“requires in essence the Court to determine whether the defendant is now at resentence an

eligible youth based on his earlier age, and consider the presence or absence of factors set

forth in the statute.” The court found that although defendant “was not the sole participant

in the crime,” “his participation was not relatively minor by his admission that it was his

weapon and that he illegally possessed it.” Moreover, the court identified no “mitigating

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circumstances that bear directly upon the manner in which the crime was committed,

namely mitigating factors to be concluded as requiring youthful offender adjudication.”

Additionally, the court expressly acknowledged an Appellate Division ruling, People v

Dukes, which had remitted a different case because the court had not considered those

factors (147 AD3d 1534 [2017]), and made clear that it was “now placing on the record as

required by statute” the “required criteria.” Finally, the court stated that “this was, of

course, an armed felony, Criminal Possession of a Weapon in the Second Degree, and as

such there are aggravating factors as opposed to mitigating factors in light of the

defendant’s participation which negate against a finding of youthful offender

adjudication.” Accordingly, the court determined “that the presence of the relevant factors

that must be decided do not appear applicable in the case at bar.” The court ultimately

imposed the same sentence that the defendant had previously negotiated: ten years of

imprisonment, followed by five years of post-release supervision. Defendant appealed his

resentence.

The Appellate Division unanimously affirmed, holding that the sentencing court

“did not err in concluding that defendant was not eligible to be adjudicated a youthful

offender,” given “defendant’s display of the weapon and his implicit threat to use it” (202

AD3d 1480, 1480-1481 [2022]).

Criminal Procedure Law § 720.10 governs adjudication of youthful offender status.

Subdivisions (1) and (2) define an “eligible youth” to include “every” “person charged with

a crime alleged to have been committed when he was at least sixteen years old and less

than nineteen years old,” “unless,” in relevant part, “the conviction to be replaced by a

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youthful offender finding is for . . . an armed felony” (CPL § 720.10 [1]; [2]). Subdivision

(3) allows a youth convicted of an armed felony offense to nonetheless be treated as eligible

if the court finds: “(i) mitigating circumstances that bear directly upon the manner in which

the crime was committed; or (ii) where the defendant was not the sole participant in the

crime, the defendant’s participation was relatively minor although not so minor as to

constitute a defense to the prosecution” (CPL 720.10 [3]).

Defendant’s contention that the sentencing court failed to exercise its discretion to

determine whether mitigating circumstances existed relies upon two lines from his

resentencing proceedings. First, the court stated that “this was, of course, an armed felony,

Criminal Possession of a Weapon in the Second Degree, and as such there are aggravating

factors as opposed to mitigating factors in light of the defendant’s participation which

negate against a finding of youthful offender adjudication” (emphasis added). According

to defendant, this statement reflects a mistaken view that the mere designation of an offense

as an armed felony precludes a finding of mitigating circumstances. Second, the court

stated that it did not find any mitigating factors present that “require[ed] youthful offender

adjudication,” and defendant argues that mitigating circumstances need only permit, not

require, youthful adjudication.

While neither of these isolated statements was the most artful articulation of the

relevant standards, the record indicates that the sentencing court applied the correct

statutory framework and exercised its discretion pursuant to the statute. The judge quoted

directly from CPL 720.10 (3) and explicitly referenced his “discretion” to determine

whether the statutory factors were present, specifically including “mitigating

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circumstances.” As required, the court expressly found that mitigating circumstances did

not exist. In any event, the Appellate Division correctly held that there were insufficient

mitigating circumstances to support youthful offender adjudication, given the threatening

manner in which defendant used the gun.

Defendant’s remaining challenges based on the recent U.S. Supreme Court decision

in New York State Rifle & Pistol Assn., Inc. v Bruen, 142 S Ct 2111 (2022), are unpreserved

and thus unreviewable for the reasons stated in People v Cabrera (decided today). Nor is

the preservation exception “permitting appellate review when a sentence’s illegality is

readily discernible from the trial record” applicable (People v Santiago, 22 NY3d 900, 903

[2013]). As we note in Cabrera, Bruen alone does not compel the conclusion that New

York’s criminal possession of a weapon statutes are unconstitutional, particularly absent

the development of a record in the trial court. We therefore do not reach defendant’s

contention that the Second Amendment bars classification of unlicensed public possession

as a violent armed felony such that he should have been eligible for youthful offender status

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