New York Court of Appeals

The People v. Santino Guerra

March 16, 2023

Summary

The Court of Appeals affirmed the order upholding a limiting instruction that barred the jury from using the victim's prior violent acts to determine whether he was the initial aggressor in the defendant's justification defense. The court declined to abandon the established rule permitting evidence of a victim's specific prior violent acts for that purpose only when the defendant knew of the acts at the time of the incident, and it rejected the defendant's constitutional challenge to that rule.