62 N.Y.2d 755 (1984)
A court’s evidentiary rulings will not result in reversal if there is no reasonable possibility that the rulings contributed to the defendant’s conviction and are thus considered harmless beyond a reasonable doubt.
Summary
Defendant Malizia was convicted of felony murder, common-law murder, attempted murder, and assault. The key witness, Harry Terrell, was the brother of the deceased. Malizia appealed, arguing insufficient evidence due to Terrell’s lack of credibility and errors in evidentiary rulings. The Court of Appeals affirmed the conviction, holding that the evidence supported the verdict and any evidentiary errors were harmless because Terrell’s character and criminal activities were thoroughly presented to the jury. The court also addressed the preservation of objections for appellate review.
Facts
William Terrell and his brother, Harry, drove to a deserted street to meet Malizia to buy drugs and pay for past purchases. Harry waited in the car while William met with Malizia and others. The jury found that Malizia shot William and then attempted to kill Harry as he fled. William’s body was later found several miles away.
Procedural History
An initial trial resulted in a hung jury. Malizia was convicted in a second trial. The Appellate Division affirmed the conviction. Malizia appealed to the New York Court of Appeals.
Issue(s)
1. Whether the evidence presented was sufficient to support the guilty verdicts, considering the credibility of the People’s main witness.
2. Whether the trial court made reversible errors in its evidentiary rulings regarding Harry Terrell’s testimony and cross-examination.
3. Whether objections to certain testimony were properly preserved for appellate review.
Holding
1. Yes, because the record contains sufficient evidence in quantity and quality to support the verdicts, and credibility is a matter for the jury to determine.
2. No, because even if the court erred in its evidentiary rulings, there was no reasonable possibility that these rulings contributed to the defendant’s conviction; thus, any errors were harmless beyond a reasonable doubt.
3. No, because the defendant did not properly object to the testimony at the second trial, nor did he bring the prior ruling to the attention of the second judge.
Court’s Reasoning
The Court of Appeals reviewed the evidence in the light most favorable to the People, acknowledging that credibility is for the jury to decide. Finding sufficient evidence to support the verdicts, the court deferred to the jury’s assessment of witness credibility.
Regarding evidentiary rulings, the court applied the harmless error standard from People v. Crimmins, 36 N.Y.2d 230, 237, stating that reversal is not required if there was no reasonable possibility that the rulings contributed to the conviction. The court noted that Harry Terrell’s extensive criminal history was fully presented to the jury, mitigating any potential prejudice from the challenged rulings.
The court addressed the defendant’s claim that a prior evidentiary ruling from the first trial was binding in the second trial as the “law of the case.” The court rejected this argument, explaining that evidentiary rulings from one trial are generally not binding in subsequent trials, especially when the prior ruling was not brought to the attention of the second judge. Furthermore, the defendant failed to properly object to the testimony at the second trial. As such, the court determined that this argument was not preserved for appellate review.
The court emphasized the need for specific and timely objections to preserve issues for appeal. The court stated, “Evidentiary rulings made at one trial, however, are normally not binding in a subsequent trial. In this case there is nothing in the record to indicate that the earlier ruling was brought to the attention of the second Judge or that he or counsel considered themselves bound by it.”