People v. Antommarchi, 80 N.Y.2d 247 (1992)
A verdict is not considered coerced simply because the jury deliberated for an extended period, even late into the night, as long as there is no evidence of juror distress or a request to be discharged, and the defendant did not request a recess.
Summary
The New York Court of Appeals upheld the defendant’s conviction, finding no evidence that the jury’s verdict was coerced despite lengthy deliberations concluding at 3:27 a.m. The jury had indicated difficulty reaching a unanimous verdict earlier in the night but did not express distress or request discharge. The defense did not request supplemental instructions or a recess in deliberations. The court reasoned that the lateness of the hour alone did not indicate coercion, and the defendant’s other contentions were without merit.
Facts
The defendant was convicted after a second trial. The jury deliberated through the afternoon and evening. At 2:14 a.m., the jury sent a note indicating they could not reach a unanimous verdict. The trial judge recited the law. The jury did not ask to be discharged or express any distress. The jury requested and received additional time before reaching a verdict at 3:27 a.m.
Procedural History
The defendant was convicted at trial. The Appellate Division affirmed the conviction. The case was appealed to the New York Court of Appeals.
Issue(s)
Whether the jury’s verdict was coerced due to the lateness of the hour and the trial court’s handling of the jury’s indication that they were unable to reach a unanimous verdict.
Holding
No, because there was no evidence of juror distress, no request from the jury to be discharged, and no request from the defense for supplemental instructions or a recess.
Court’s Reasoning
The court acknowledged the importance of avoiding coerced verdicts. However, the court found no basis to conclude coercion occurred in this case. The court emphasized that the jury did not express fatigue or distress when they indicated difficulty reaching a verdict. The defense’s failure to request supplemental instructions or a recess was also noted. The court highlighted that the jury requested additional time before reaching a verdict, suggesting they were willing to continue deliberating. The Court of Appeals deferred to the Appellate Division’s judgment, finding nothing in the record to suggest coercion based solely on the late hour. The court stated, “We agree with the Appellate Division that there is nothing in this record to suggest that the lateness of the hour or the action of the court coerced the verdict.”