People v. Matthews, 50 N.Y.2d 913 (1980)
In a larceny case, failure to include statutory definitions of “deprive” and “appropriate” in the jury charge, when requested, constitutes reversible error, regardless of whether the larcenous intent issue is unique or difficult.
Summary
The New York Court of Appeals reversed the Appellate Term’s order and remitted the case to the Criminal Court. The court held that the trial judge’s failure to include the statutory definitions of “deprive” and “appropriate” in the jury charge, despite a request to do so, was reversible error. The Court of Appeals rejected the Appellate Term’s reasoning that such definitions are only required when a “unique and difficult” larcenous intent issue is present. The Court found that omitting these definitions could mislead the jury into believing any withholding, temporary or permanent, constitutes larceny.
Facts
The prosecution presented evidence that the defendant was observed striking several women in the back of the head. Following this, he allegedly reached out and pulled an earring from a victim. The earring fell to the ground. By the time the defendant was arrested, both the victim and the earring had disappeared from the scene.
Procedural History
The defendant was tried in the Criminal Court, New York County, for attempted larceny. The trial judge did not include the statutory definitions of “deprive” and “appropriate” in the jury charge, despite a request for their inclusion. The defendant was convicted. The Appellate Term affirmed the conviction, reasoning that the statutory definitions were not required because there was no “unique and difficult” larcenous intent issue present. The case was then appealed to the New York Court of Appeals.
Issue(s)
Whether the failure of the trial judge to include the statutory definitions of “deprive” and “appropriate” in the jury charge, when requested by the defense, constitutes reversible error in an attempted larceny case.
Holding
Yes, because the omission of the statutory definitions could have misled the jury into thinking that any withholding, permanent or temporary, constitutes larceny.
Court’s Reasoning
The Court of Appeals held that the trial judge’s failure to include the statutory definitions of “deprive” and “appropriate” (Penal Law § 155.00, subds 3, 4) was reversible error. The court emphasized that there is no requirement for a “unique and difficult” larcenous intent issue to be present before such definitions must be provided to the jury. The court reasoned that without these definitions, the jury could have been misled into believing that any withholding, whether permanent or temporary, would constitute larceny. The court agreed with Justice Sandifer’s dissent in the Appellate Term, quoting that the omission “could have misled the jury into thinking that any withholding, permanent or temporary, constituted larceny.” This highlights the importance of accurately conveying the legal meaning of key terms to the jury to ensure a fair trial. The court’s decision underscored the necessity of precise jury instructions, especially when dealing with elements of a crime that have specific statutory definitions. This ensures that the jury understands the specific intent required for a larceny conviction, avoiding the potential for convicting a defendant based on conduct that doesn’t meet the statutory requirements. The practical impact of this decision is that trial judges must include statutory definitions of key terms when requested, even if the case does not present particularly complex issues of intent. This provides a clearer framework for the jury to apply the law to the facts.