People v. Snyder, 73 N.Y.2d 900 (1989)
When a defendant disarms another of a weapon, their subsequent actions demonstrating an intent to retain possession and not immediately relinquish it to authorities negates a claim of innocent, temporary possession.
Summary
Wayne and Robert Snyder assaulted Bruce Van Allen outside a bar, taking his loaded pistol. Instead of contacting the nearby State Police, the brothers went home to discuss hiding the gun. Wayne removed the clip and hid it. The next day, police retrieved the gun. The New York Court of Appeals held that the Snyders were not entitled to a jury instruction on temporary lawful possession because their actions were inconsistent with a claim of innocent possession resulting from disarming a wrongful possessor. Their behavior indicated intent to retain the weapon rather than relinquish it. This decision clarifies the limits of the temporary and lawful possession defense.
Facts
Two brothers, Wayne and Robert Snyder, assaulted Bruce Van Allen outside a bar.
During the altercation, the Snyders wrested a loaded pistol from Van Allen.
After obtaining the gun, the brothers walked to their nearby home.
They discussed what to do with the gun, considering options such as throwing it in a river, burying it, or placing it in a mailbox.
Ultimately, they decided to postpone deciding what to do with the gun until the next day.
The Snyders did not report the incident to the State Police, despite the barracks being close to the bar.
Wayne Snyder removed the clip from the gun and hid it under his bed.
The police retrieved the gun the next morning.
Procedural History
The defendants were convicted of criminal possession of a weapon.
They appealed, arguing they were entitled to a jury instruction on temporary lawful possession of the weapon.
The Appellate Division affirmed the convictions.
The case then went to the New York Court of Appeals.
Issue(s)
Whether the defendants were entitled to a jury instruction on temporary and lawful possession of a weapon where they disarmed another person but then failed to turn the weapon over to police and instead discussed hiding it.
Holding
No, because there was no reasonable view of the evidence under which the jury could have found the defendants’ possession of the weapon to be innocent. Their actions were utterly at odds with a claim of innocent possession resulting from disarming a wrongful possessor.
Court’s Reasoning
The Court of Appeals agreed with the Appellate Division, finding no reasonable view of the evidence supporting a finding that the defendants’ possession of the weapon was innocent.
The court emphasized that the defendants’ actions after disarming Van Allen contradicted a claim of temporary and lawful possession.
Specifically, the court noted that the defendants discussed hiding the gun, considered various disposal methods, and postponed deciding what to do with it until the next day, rather than immediately contacting law enforcement.
Wayne Snyder’s act of removing the clip from the gun and hiding it under his bed further demonstrated an intent to retain possession rather than relinquish it.
The court distinguished the case from situations where possession is temporary and incidental to disarming a wrongful possessor, citing People v. Persce, 204 NY 397, 402.
The court quoted People v. Williams, 50 NY2d 1043, 1045, stating that the evidence was “utterly at odds with [defendants’] claim of innocent possession”.
The court found that the Snyders actions went beyond merely disarming Van Allen and indicated an intention to unlawfully possess the weapon. Their conduct, including hiding the weapon and failing to notify the police, demonstrated that they sought to exercise dominion and control over the weapon rather than relinquish it to the authorities.