People v. Young, 48 N.Y.2d 995 (1980)
A defendant’s inculpatory statements are admissible if they were voluntarily made following a knowing and intelligent waiver of the rights to counsel and to remain silent; a mistrial is not warranted for peripheral references to other criminal acts if less drastic means can alleviate potential prejudice.
Summary
The New York Court of Appeals affirmed the lower court’s decision, holding that the defendant’s confession was admissible because it was voluntarily made after a valid waiver of his rights. The Court also found that the trial court did not err in denying the defendant’s requests for a mistrial, which were based on peripheral references to another alleged criminal act, because less drastic means of addressing any potential prejudice were available and, in one instance, actively pursued through a jury instruction.
Facts
The defendant, Jerry Young, made inculpatory statements. Prior to trial, Young moved to suppress these statements, arguing that they were not voluntarily made. During the trial, peripheral references were made to another criminal act allegedly committed by the defendant. The defendant requested a mistrial based on these references.
Procedural History
The Supreme Court found that the defendant’s inculpatory statements were voluntary and admissible. The Appellate Division affirmed the Supreme Court’s decision. The defendant appealed to the New York Court of Appeals.
Issue(s)
1. Whether the defendant’s inculpatory statements were voluntarily made following an effective waiver of his rights to counsel and to remain silent.
2. Whether the trial court erred in denying the defendant’s requests for a mistrial based on peripheral references to another criminal act allegedly performed by the defendant.
Holding
1. No, because the record supports the finding that the inculpatory statements were voluntarily made after a valid waiver of rights.
2. No, because less drastic means of alleviating whatever prejudice may have resulted from the references were available.
Court’s Reasoning
The Court of Appeals deferred to the factual finding of the Supreme Court, as affirmed by the Appellate Division, that the defendant’s statements were voluntarily made following an effective waiver of his rights. The Court emphasized that it found no basis for disturbing this finding.
Regarding the mistrial requests, the Court stated that a mistrial was not mandated because less drastic means were available to alleviate any potential prejudice. In one instance, the trial court instructed the jury to disregard the testimony. In another, the court indicated a willingness to consider a request to address the issue. The Court noted that the defendant insisted on a mistrial instead of pursuing these less drastic alternatives.
The court stated, “Our examination of the record persuades us that there exists no basis for disturbing the factual finding made by Supreme Court and affirmed by the Appellate Division that the inculpatory statements had been voluntarily made by defendant following an effective waiver of his rights to counsel and to remain silent.”