People v. Thomas, 50 N.Y.2d 467 (1980)
A defendant must object to jury instructions at trial to preserve a claim of error for appellate review unless the instruction expressly shifts the burden of proof to the defendant or explicitly relieves the prosecution of proving every element of the crime.
Summary
Thomas was convicted of murder for the stabbing deaths of a woman and her two children. On appeal, he argued that the trial court’s instruction on intent, stating that a person is presumed to intend the natural and probable consequences of their acts, violated due process under Sandstrom v. Montana. The Appellate Division reversed, but the Court of Appeals reversed again, holding that because Thomas’s attorney did not object to the instruction at trial, the error was not preserved for appellate review. The court emphasized the importance of preserving errors at trial to allow for correction and avoid unnecessary appeals.
Facts
The defendant, Thomas, was accused of murdering Deborah Williams and her two young daughters in their apartment. Thomas initially denied involvement, but later confessed to stabbing the victims after an argument with Williams. He claimed she was seeing another man. The victims suffered numerous stab wounds, and the children’s skulls were fractured. At trial, Thomas recanted his confession, claiming coercion by the police.
Procedural History
Thomas was convicted of three counts of second-degree murder in the Bronx County Supreme Court. The Appellate Division reversed the conviction and ordered a new trial, finding the jury instruction on intent violated Sandstrom v. Montana and was reviewable despite the lack of objection at trial. The People appealed to the New York Court of Appeals.
Issue(s)
Whether a defendant’s failure to object to a jury instruction at trial precludes appellate review of the instruction, even if the instruction allegedly violates due process by creating an impermissible presumption of intent.
Holding
No, because the defendant did not object to the jury instruction at trial, and the instruction did not expressly shift the burden of proof to the defendant or relieve the prosecution of its burden; therefore, the alleged error was not preserved for appellate review.
Court’s Reasoning
The Court of Appeals emphasized the general rule that issues not raised at trial are waived on appeal. While there is a narrow exception for fundamental constitutional rights deprivations, this exception only applies when the trial procedure deviates in a basic way from constitutional or statutory mandates. The Court distinguished this case from People v. Patterson, where the defendant challenged the constitutionality of a statute that explicitly placed the burden of proving an affirmative defense on the defendant. Here, the trial court specifically instructed the jury that the People had the burden of proving guilt beyond a reasonable doubt, and there was no explicit shifting of the burden. The court noted that while the instruction regarding the presumption of intent could be interpreted as shifting the burden, this did not rise to the level of a fundamental defect requiring no preservation. The court acknowledged Sandstrom v. Montana, but stated that this case did not change New York law because the court has held similar charges to be erroneous as a matter of State law for over a century. Because the Appellate Division erroneously reversed on the law, the Court of Appeals reversed the Appellate Division’s order and remitted the case for review of the facts.