People v. Reynolds, 16 N.Y.2d 241 (1965)
A statute prohibiting selling or giving alcohol to minors should not be interpreted to criminalize serving alcohol to minors in a private residence, absent clear legislative intent.
Summary
Defendant was convicted of violating a statute prohibiting the sale or provision of alcohol to minors after she permitted several minors to drink alcohol in her home. The New York Court of Appeals reversed the conviction, holding that the statute was not intended to apply to the private serving of alcohol to minors in a home. The court reasoned that the statute should be read in its entirety and considered in the context of other provisions addressing commercial activities involving children. The court applied the principle of noscitur a sociis, interpreting the statute’s scope by considering associated words and the overall purpose of the law.
Facts
Defendant permitted four individuals under the age of 18 to congregate in her home and served them alcoholic beverages on multiple occasions over a six-month period.
Procedural History
The Dutchess County Court convicted the defendant of violating section 484(3) of the Penal Law. The Appellate Term affirmed the County Court’s judgment. The New York Court of Appeals granted permission for the defendant to appeal the Appellate Term’s affirmance.
Issue(s)
Whether subdivision 3 of section 484 of the Penal Law, which prohibits selling or giving alcohol to persons under 18, applies to the act of serving alcohol to minors in a private home.
Holding
No, because the legislative intent behind section 484 was not to criminalize the serving of alcoholic beverages to minors in a private residence.
Court’s Reasoning
The court reasoned that statutory interpretation requires considering the entire statute to ascertain legislative intent. Section 484, titled “Permitting children to attend certain resorts,” primarily addresses commercial activities involving children. The court applied the rule of noscitur a sociis (or ejusdem generis), which suggests that the meaning of a word or phrase should be determined by the company it keeps. Therefore, the statute’s prohibition on giving alcohol to minors should be understood in the context of other provisions that forbid harmful commercial activities involving children.
The court emphasized that interpreting the statute to criminalize serving alcohol in a private residence would be an unreasonable reading. The court noted the absence of prior prosecutions under the statute for such conduct, further supporting its interpretation.
The court stated: “Section 484 shows an absence of legislative intent to penalize acts like defendant’s, not only by its title (“ Permitting children to attend certain resorts”) but also by the linking of subdivision 3 (supra) with six other subdivisions each of which forbids certain commercial activities with children which are thought to be harmful to the children.”