New York Court of Appeals

The People of the State of New York, Respondent v. Duval Irizarry, Appellant

May 3, 199483 N.Y.2d 557

Summary

The Court affirmed the conviction, holding that the failure to seal the first jury's verdict in a dual‑jury trial does not require reversal absent a showing of prejudice, that the safeguards in People v. Ricardo B. are guidelines rather than mandatory constitutional requirements, and that the same prejudice standard applies to dual‑jury trials as to single‑jury trials.