83 N.Y.2d 791 (1994)
A defendant’s conviction on valid, independent charges should not be overturned on the basis of prejudice stemming from evidence related to charges on which the defendant was acquitted, unless it can be shown that such prejudice nullified the valid conviction.
Summary
Alexander Brown was convicted of robbery and attempted murder. The Appellate Division reversed, arguing that the introduction of evidence related to felony murder charges (of which Brown was acquitted) prejudiced the jury’s consideration of the robbery and attempted murder charges. The Court of Appeals reversed the Appellate Division, holding that the introduction of evidence pertaining to a charge for which the defendant was acquitted does not automatically nullify a conviction on other independent charges, unless the prejudice is so great as to deny a fair trial on those charges. The case was remitted to the Appellate Division for factual review.
Facts
Alexander Brown and an accomplice stole a gold chain. When the victim gave chase, Brown displayed a gun. Brown and his accomplice fled in a car with two other occupants. The victim and a friend chased Brown’s vehicle. The victim broke the rear window of Brown’s car with a baseball bat, and Brown fired two shots in response. Police officers joined the chase, which ended when Brown’s vehicle crashed. Brown then stole a police car. Responding to the report of the stolen police car, other officers collided with an ambulance, resulting in an officer’s death. Brown was apprehended and indicted on numerous charges, including felony murder related to the officer’s death.
Procedural History
The trial court denied Brown’s motion to dismiss the felony murder and first-degree assault counts. After a jury trial, Brown was acquitted of the felony murder and first-degree assault counts but convicted of robbery and attempted murder. The Appellate Division reversed the conviction, holding that the trial court erred in denying Brown’s motion to dismiss the felony murder counts and that the introduction of evidence related to felony murder prejudiced the jury’s consideration of the counts on which he was convicted. The Court of Appeals reversed and remitted the case to the Appellate Division for consideration of the facts.
Issue(s)
Whether the introduction of testimony regarding the felony murder count so prejudiced the jury as to have deprived the defendant of a fair trial on separate and unrelated charges for which he was convicted.
Holding
No, because prejudice does not nullify an independent, validly secured robbery and attempted murder conviction as a matter of law.
Court’s Reasoning
The Court of Appeals disagreed with the Appellate Division’s ruling that the introduction of evidence related to the felony murder charge, for which Brown was acquitted, automatically prejudiced the jury’s consideration of the robbery and attempted murder charges. The Court found that the Appellate Division erred in ruling “as a matter of law that prejudice nullified an independent, validly secured robbery and attempted murder conviction.” The Court implied that a valid conviction should only be overturned if the prejudice stemming from evidence related to the acquitted charge was so significant that it deprived the defendant of a fair trial on the other charges. The Court therefore reversed the Appellate Division’s order and remitted the case for further factual review, implying that the Appellate Division should determine whether the prejudice was, in fact, so significant as to warrant a new trial.