The People of the State of New York, Appellant v. Timothy Wood, Respondent

Summary

The New York Court of Appeals affirmed the Appellate Division's reversal of Timothy Wood's criminal contempt convictions, holding that the prosecution violated the Double Jeopardy Clause because the prior Family Court contempt conviction was a lesser‑included offense of the criminal contempt offense. The Court applied the Blockburger test and concluded that the two statutes do not contain distinct elements.