New York Court of Appeals
People v. Finley
June 10, 200810 N.Y.3d 647
Summary
The New York Court of Appeals held that small amounts of marijuana possessed by inmates do not constitute "dangerous contraband" under Penal Law §§205.00(4) and 205.25(2). Accordingly, the felony convictions for first‑degree promotion of prison contraband in both People v. Salters and People v. Finley were reduced to the lesser misdemeanor offenses and the cases were remanded for resentencing. The Court based its decision on a textual and legislative‑history analysis of the statute.