People v. Glass, 34 N.Y.2d 451 (1974)
Evidence of good character, when believed by the jury and considered with all other evidence, may be sufficient to raise a reasonable doubt as to a defendant’s guilt, but it is not, standing alone, automatically sufficient to create such a doubt.
Summary
The defendants were convicted of grand larceny and issuing a false financial statement. At trial, they requested a jury charge stating that evidence of previous good character could, standing alone, be sufficient to create a reasonable doubt. The trial court refused to include the “standing alone” portion in its charge, and the defendants appealed. The New York Court of Appeals affirmed the convictions, holding that while character evidence is a significant factor, it’s not automatically sufficient to create reasonable doubt; it must be considered in conjunction with all other evidence in the case.
Facts
The individual defendants were convicted on multiple counts of grand larceny and issuing a false financial statement. During the trial, the defense presented witnesses who testified to the defendants’ good character and reputation in the community.
Procedural History
The trial court convicted the defendants. The Appellate Division unanimously affirmed the judgments of conviction without opinion. The case then went to the New York Court of Appeals, challenging the jury instructions regarding character evidence.
Issue(s)
Whether the trial court committed reversible error by refusing to charge the jury that character evidence, standing alone, may be sufficient to create a reasonable doubt, and instead instructing the jury that character evidence is not, in and of itself, sufficient to raise a reasonable doubt.
Holding
No, because evidence of good character is but one fact to be weighed with the other facts in the case; its influence depends greatly on the other evidence presented. It is not sufficient, on its own, to create reasonable doubt but may do so when believed and considered with all other evidence.
Court’s Reasoning
The court addressed the argument that character evidence alone can create reasonable doubt, referencing conflicting precedents. The Court of Appeals clarified that while character evidence is a substantial matter and must be considered by the jury, its weight depends on the context of all other evidence. The court cited People v. Trimarchi, stating: “Evidence of good character is not, of itself, sufficient to raise a reasonable doubt. Such evidence, in order to raise a reasonable doubt, must be believed by the jury. It then may, when considered with all the other evidence in the case, be sufficient to raise a reasonable doubt as to his guilt.” The court reasoned that character evidence aims to show the improbability that a person of good character would commit the crime. However, its impact varies based on the strength and reliability of the evidence against the defendant. The court emphasized the importance of viewing the jury charge as a whole, finding no reversible error in this context. The court stated, “Character evidence does not exist in a vacuum, and its value, influence or the weight to be accorded it depends in great part upon the other evidence in the case. If accepted and believed, it becomes a fact to be weighed with the other facts.” The court effectively distinguished this case from others where a different charge was required. Therefore, the trial court’s instruction, viewed in its entirety, was deemed appropriate.