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Fourth Department – Sandoval ruling: People v. Grefer
Daily Record Staff//June 22, 2026//
New York State Supreme Court, Appellate Division, Fourth Judicial Department
Sandoval ruling — Mistrial
KA 23-01584
Appealed from Cayuga County Court
Background: The defendant appealed from his conviction of two counts of offering a false instrument for filing. He falsely reported on an employment application for a position with the county that he was never convicted of a crime and falsely stated on a resume accompanying the employment application that he was a licensed mental health counselor. He argues that the court erred by denying his motion for a mistrial after the prosecutor violated the court’s Sandoval ruling.
Ruling: The Appellate Division affirmed. The court held that the defendant opened the door to the prosecutor’s questioning about the defendant’s prior conviction. Thus, a mistrial was not warranted.
David P. Elkovitch for the defendant-appellant; Christopher T. Valdina, of the district attorney’s office, for the respondent.
Submitted
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