People v. Brown, 36 N.Y.2d 626 (1975)
A defendant seeking to assert a justification defense to the crime of escape must make an explicit tender of specific proof regarding the conditions that purportedly justify the escape; broad, general allegations of cruel and inhuman treatment are insufficient to warrant the admission of evidence on the defense.
Summary
Defendants were convicted of escape in the first degree. They appealed, arguing they were improperly denied the opportunity to present a justification defense based on cruel and inhuman treatment in the Monroe County Penitentiary. The Court of Appeals affirmed the convictions, holding that the defendants failed to make a sufficiently specific proffer of evidence to support the justification defense. The court emphasized that the defense counsel only made broad, general allegations without providing any concrete details about the alleged mistreatment. Because of this lack of specificity, the trial court did not commit reversible error by curtailing the defense’s attempt to present evidence of the jail conditions.
Facts
The defendants escaped from the Monroe County Penitentiary. At trial, they sought to argue that their escape was justified due to cruel and inhuman treatment they allegedly experienced while incarcerated. The defense counsel made general references to these conditions but did not provide specific details or a formal proffer of evidence detailing the alleged mistreatment.
Procedural History
The defendants were convicted of escape in the first degree. They appealed, arguing that they were denied the right to present a justification defense. The Appellate Division affirmed the convictions. The case then went to the New York Court of Appeals.
Issue(s)
Whether a trial court errs in curtailing a defendant’s attempt to present a justification defense to the charge of escape, when the defendant’s proffer of evidence consists of only broad, general allegations of cruel and inhuman treatment without specific details.
Holding
No, because a defendant must make an explicit tender of specific proof as to the conditions on which the justification defense is predicated; broad, general allegations are insufficient to require the court to admit evidence on the defense.
Court’s Reasoning
The Court of Appeals affirmed the lower court’s decision, emphasizing the lack of specific details in the defendants’ proffer of evidence. The court noted that defense counsel only made