New York Court of Appeals

The People of the State of New York v. Jamel Walston

June 12, 201423 N.Y.3d 986

Summary

The Court of Appeals vacated the defendant's first‑degree manslaughter conviction because the trial judge failed to give counsel meaningful notice of a jury note, deeming the error a mode of proceedings error under People v. O'Rama, and remanded for a new grand‑jury charge and resentencing on the weapon‑possession conviction, which was affirmed. Justice Smith, in a concurring opinion, agreed with the holding but urged future reconsideration of O'Rama's precedent.