New York Court of Appeals

The People of the State of New York, Respondent v. Carlos Santos, Appellant

October 31, 199586 N.Y.2d 869

Summary

The Court of Appeals affirmed the Appellate Division's order, holding that a defendant's general motion to dismiss for insufficiency after a bench trial raises a question of law and therefore requires a specific objection to preserve the issue for appellate review. The Gray‑Bynum rule, which mandates such an objection in jury trials, was applied equally to bench trials, and the Court overruled the earlier decision in People v. Nixon.