New York Court of Appeals
The People of the State of New York, Respondent v. Edwin Vasquez, Appellant; In the Matter of Jose Cordero…
March 20, 199789 N.Y.2d 521
Summary
The New York Court of Appeals affirmed the lower courts, holding that prison disciplinary sanctions are not criminal punishment for double jeopardy purposes and that the statutory double jeopardy provision of CPL article 40 does not bar subsequent criminal prosecution. The court rejected the application of the Halper balancing test and relied on longstanding case law that internal prison discipline serves non‑criminal institutional interests.