People v. Allen, 69 N.Y.2d 915 (1987)
A general objection to a jury instruction, without specifying the grounds, is insufficient to preserve the issue for appellate review.
Summary
Defendant Allen was convicted of second-degree murder. On appeal, he argued that the trial court’s jury instruction on intoxication violated his due process rights by improperly shifting the burden of proof or unduly emphasizing credibility. However, the Court of Appeals affirmed the conviction, holding that Allen’s general objection to the instruction at trial was insufficient to preserve the issue for appellate review because he did not specifically articulate the basis for his objection to the trial judge. The court emphasized that specific and timely objections are needed to allow the trial court to correct any errors.
Facts
The defendant, Barry Allen, was convicted of murder in the second degree. During the trial, jury instructions regarding intoxication were given. The specific facts surrounding the murder itself are not detailed in this memorandum opinion, as the appeal focuses solely on the propriety of the jury instructions.
Procedural History
The defendant was convicted of murder in the second degree in the trial court. He appealed to the Appellate Division, which affirmed the conviction. He then appealed to the New York Court of Appeals.
Issue(s)
1. Whether the trial court erred in denying reinstruction on intoxication in the supplemental charge to the jury when the jury only asked for reinstruction on the elements of the crime charged.
2. Whether the defendant adequately preserved for appellate review his objection to the primary instruction on intoxication, framed as a violation of due process, when his objection to the Trial Judge was unparticularized.
Holding
1. No, because the jury did not request reinstruction on intoxication, but only on the elements of the crime charged.
2. No, because the defendant’s objection to the intoxication instruction was unparticularized and did not specify the grounds for the objection.
Court’s Reasoning
The Court of Appeals held that the defendant’s argument concerning the failure to re-instruct on intoxication was without merit because the jury only requested reinstruction on the elements of the crime. More importantly, the court addressed the defendant’s objection to the initial intoxication instruction. The court emphasized the need for specific objections at trial to allow the trial judge an opportunity to correct any potential errors. Here, the defendant’s objection was deemed too general. The Court stated that the objection was “not so framed as an objection expressed to the Trial Judge, and is not adequately preserved by the unparticularized objection to the intoxication instruction.” By failing to articulate the specific basis for his objection—namely, that the instruction shifted the burden of proof or unduly emphasized credibility—the defendant forfeited his right to raise the issue on appeal. The Court of Appeals effectively reinforced the contemporaneous objection rule, which requires parties to raise objections at the time of the alleged error to preserve the issue for appellate review. This rule prevents “sandbagging” the trial court and ensures fairness to both parties. The court did not elaborate further, issuing a memorandum opinion, implying the issue was well-settled.