The People of the State of New York v. Daniel Boyer, Appellant the People of the State of New York v. Equan Sanders

Summary

The Court held that the original sentencing date of a prior conviction controls for the sequentiality requirement in New York’s recidivist sentencing statutes, affirming the Boyer judgment and reversing the Sanders judgment with a remand for resentencing as a persistent violent felony offender. Justice Rivera dissented, arguing that an illegal sentence must be vacated and resentenced before it can be used for enhancement.