Fourth Department – Sandoval: People v. Thomas

New York State Supreme Court, Appellate Division, Fourth Judicial Department

Sandoval

Defendant’s credibility – Probative

People v. Thomas

KA 18-02057

Appealed from Supreme Court, Monroe County

Background: The defendant appealed from his conviction of criminal sexual act and rape. He argues that the court abused its discretion with its Sandoval ruling because the court did not provide a detailed recitation of its underlying reasoning.

Ruling: The Appellate Division affirmed. The court held that a trial court’s discretion should not be disturbed merely because the court did not provide a detailed explanation of its reasoning, particularly where the basis of the court’s decision may be inferred from the parties’ arguments. Moreover, the convictions on which the court permitted inquiry were probative of the defendant’s credibility inasmuch as such acts showed the willingness of the defendant to place the advancement of his individual self-interest ahead of principle or the interests of society. Also, as the defendant was the only possible witness for the defense concerning certain allegations increased the importance of his credibility and his testimony.

Paul Skip Laisure, of the public defender’s office, for the defendant-appellant; Martin P. McCarthy II, of the district attorney’s office, for the respondent.

Oral argument video