People v. Alcide, 56 N.Y.2d 964 (1982)
A court’s failure to respond to a jury note constitutes reversible error only if it seriously prejudices the defendant, and an interested witness charge is proper when the court instructs the jury that they may consider whether any witness has an interest in the outcome of the case.
Summary
The defendant appealed his conviction, arguing that the trial court erred by not responding to a jury note and by improperly instructing the jury on interested witnesses. The jury note concerned two jurors’ request to be dismissed before sundown due to Sabbath observance. The Court of Appeals affirmed the Appellate Division’s order, holding that the failure to respond to the jury note did not seriously prejudice the defendant and that the interested witness charge was proper because the court instructed the jury that they could consider whether any witness had an interest in the outcome of the case.
Facts
During jury deliberations, the jury sent out several notes requesting exhibits, readbacks, or additional instructions. On the second day, two jurors sent a note stating they were Sabbath observers and requested dismissal before sundown. The court did not respond to this note and did not inform counsel of its existence. Twenty minutes after the note was sent, the jury announced it had reached a verdict, and the court accepted the verdict without addressing the note.
Procedural History
The defendant was convicted at trial. He appealed, arguing that the trial court’s failure to respond to the jury note and the interested witness charge were errors. The Appellate Division affirmed the conviction. The defendant then appealed to the New York Court of Appeals.
Issue(s)
1. Whether the trial court’s failure to respond to the jury note regarding the jurors’ Sabbath observance constituted reversible error under CPL 310.30?
2. Whether the trial court erred in its instruction to the jury regarding interested witnesses?
Holding
1. No, because the failure to respond to the jury note did not seriously prejudice the defendant.
2. No, because the court gave a standard instruction that the jury could consider whether any witness had an interest in the outcome of the case.
Court’s Reasoning
Regarding the jury note, the court stated that CPL 310.30 requires a meaningful response to jury requests for instruction or information. However, reversal is required only where the failure to respond “seriously prejudice[s]” the defendant. The court reasoned that the note did not concern the crimes charged or the evidence, and there was no significant probability that the jurors were coerced or pressured into returning a guilty verdict because of the court’s failure to respond. The court noted that the jury reached a verdict well before sundown, negating any inference of coercion. As stated in the opinion, “It is only where the failure to respond to a jury note ‘seriously prejudice[s]’ defendant that a reversal is required”.
Regarding the interested witness charge, the court found no error because the trial court provided the standard instruction, informing the jury that they could consider whether any witness had an interest in the outcome of the case. The court clarified that merely because a witness was interested did not automatically mean that they were untruthful. The court also stated, “There is no question that defendant was an interested witness as a matter of law as the court appears to have charged”. While the judge specifically named the defendant’s wife, the instruction was not misleading, and the jury could have found any witness to be interested. The charge, viewed as a whole, was considered balanced and understandable.