New York Court of Appeals
People v. Watkins
May 23, 202442 N.Y.3d 635
Summary
The Court of Appeals affirmed the conviction, holding that trial counsel's failure to request a cross-racial identification instruction at a 2017 trial did not constitute ineffective assistance based on a single alleged error. At that time, existing law treated the instruction as discretionary, and counsel had no clear entitlement to obtain it; the later decision making the instruction mandatory upon request announced a new approach. The court therefore concluded that counsel's omission was not sufficiently egregious to deny defendant meaningful representation.