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.