New York Court of Appeals
The People of the State of New York v. Jean Yves Jean-Baptiste
November 25, 200811 N.Y.3d 539
Summary
The New York Court of Appeals affirmed the Appellate Division’s reduction of the defendant’s depraved‑indifference murder conviction to second‑degree manslaughter, holding that the Feingold standard applies to cases pending on direct appeal and that the evidence did not establish the requisite mental state. The Court applied the newer subjective standard retroactively to the defendant’s sufficiency challenge and found the lesser‑included offense supported by the record.