People v. Brown, 56 N.Y.2d 242 (1982)
A claim of ineffective assistance of counsel can be raised for the first time on appeal, but a review of the trial record alone must demonstrate that the defendant did not receive meaningful representation.
Summary
The New York Court of Appeals affirmed the Appellate Division’s order, holding that while ineffective assistance of counsel claims can be raised initially on appeal, the defendant failed to demonstrate inadequate representation based solely on the trial record. The Court acknowledged that defense counsel’s summation was not ideal, but it clarified that counsel clearly argued misidentification as the defense. Furthermore, the Court dismissed the claim of a conflict in witness descriptions as a typographical error. Absent further evidence, the Court could not conclude that defense counsel was ineffective.
Facts
The defendant was convicted after a trial. On appeal, the defendant argued that his trial counsel provided ineffective assistance. He cited alleged deficiencies in the summation and an apparent contradiction between descriptions of the defendant provided by the backup officer and the undercover officer involved in the case.
Procedural History
The case originated in a trial court where the defendant was convicted. The defendant then appealed to the Appellate Division, the decision of which was affirmed by the New York Court of Appeals. The Court of Appeals reviewed the defendant’s claim of ineffective assistance of counsel, which was raised for the first time on appeal.
Issue(s)
Whether a claim of ineffective assistance of counsel can be raised for the first time on appeal; and whether, based solely on the trial record, the defendant demonstrated that he did not receive meaningful representation.
Holding
Yes, a claim of ineffective assistance of counsel can be raised for the first time on appeal. No, because a review of the record, without more, does not bear out the claim that defendant did not have meaningful representation.
Court’s Reasoning
The Court of Appeals acknowledged that ineffective assistance of counsel claims can be raised for the first time before the court, citing People v. Baldi, 54 N.Y.2d 137. However, the Court emphasized that the record itself must demonstrate that the defendant did not receive meaningful representation. In this case, despite acknowledging that the defense counsel’s summation was not perfect, the Court found that it clearly articulated the defense of misidentification. The Court also addressed the claimed conflict between the backup officer’s and the undercover officer’s descriptions of the defendant, attributing it to a typographical error. The backup officer’s description included both