When Do Evidentiary Errors Deprive a Fair Trial? - People v. Deverow скачать в хорошем качестве

When Do Evidentiary Errors Deprive a Fair Trial? - People v. Deverow

In this video, we’ll discuss the criminal-law case of People v. Deverow, which addresses evidentiary rules regarding admissibility of 911 calls and witnesses. Importantly, the case explores the consequences of judicial errors in such rulings, and whether they constitute reversible error or harmless error. Issue: Was Defendant deprived of a fair trial by evidentiary rulings precluding 911 calls and a witness? Case Name: People v. Deverow Citation: 2022 NY Slip Op 03362 (https://www.nycourts.gov/reporter/3ds...) Oral Argument Link:    • No. 46 People v Dashawn Deverow   Publication Date: May 24, 2022 Key parts of the Decision: Overall Issue: Did the trial judge's evidentiary rulings regarding an alleged eyewitness's testimony and 911 calls deprive Defendant of his constitutional right to present a defense? Overall Holding: "Under the facts presented and upon application of our well-settled law, the effect of the trial judge's erroneous evidentiary rulings deprived defendant of his constitutional right to present a defense. Accordingly, we reverse and order a new trial." "We now hold that the trial court's evidentiary rulings regarding R.J.'s testimony and the 911 calls deprived defendant of his constitutional right to present a defense." "Criminal defendants must be afforded "a meaningful opportunity to present a complete defense" (Crane v Kentucky, 476 US 683, 690 [1986] [internal quotation marks omitted]). This fundamental right is guaranteed by the Due Process Clause of the Fourteenth Amendment and the Compulsory Process and Confrontation Clauses of the Sixth Amendment (see id.). Although this "right to present a defense does not give criminal defendants carte blanche to circumvent the rules of evidence" (People v Hayes, 17 NY3d 46, 53 [2011] [internal quotation marks omitted]), a trial court must not apply the rules "mechanistically to defeat the ends of justice" (Chambers v Mississippi, 410 US 284, 302 [1973]). Thus, "[a] court's discretion in evidentiary rulings is circumscribed by" the defendant's constitutional right to present a defense (People v Carroll, 95 NY2d 375, 385 [2000])." "Admitting the 911 calls could have allowed defendant the opportunity to buttress his justification defense, to mount a different defense, or to challenge the eyewitness's account of events. Precluding this testimony effectively tied defendant's hands. A jury should have been allowed to hear and assess the excluded information and reach a verdict after weighing all the relevant evidence." #nycourtofappeals #evidence #presentsenseimpression #911call #fairtrial