People v. Turaine, 78 N.Y.2d 871 (1991)
A defendant has the right to be present at any material stage of the trial, including preliminary hearings where adverse testimony is received, to confront witnesses and advise counsel.
Summary
The New York Court of Appeals reversed the Appellate Division’s order and mandated a new trial. The court held that the defendant’s exclusion from a pretrial hearing, where a witness testified about alleged intimidation by the defendant, constituted reversible error. The Court of Appeals reasoned that such a hearing is a material stage of the trial, as the defendant’s presence is essential for confronting adverse witnesses and assisting counsel in identifying inconsistencies or falsehoods in their testimony, impacting the defendant’s ability to defend himself effectively.
Facts
The defendant was on trial. A witness against him, detained on separate charges, was mistakenly placed in the courthouse holding pen with the defendant. The prosecutor sought to introduce testimony that the defendant threatened or intimidated the witness in the holding pen to prevent him from testifying.
Procedural History
During the trial, the court held a hearing outside the jury’s presence to determine the admissibility of the witness’s testimony regarding the alleged intimidation. The defendant was excluded from this hearing over objection. The Appellate Division upheld the original trial court decision. The New York Court of Appeals then reviewed the case.
Issue(s)
Whether a defendant’s exclusion from a pretrial hearing, where a witness testifies about alleged intimidation by the defendant, constitutes a violation of the defendant’s right to be present at all material stages of the trial.
Holding
Yes, because proceedings where testimony is received are material stages of the trial, and the defendant’s presence is necessary to confront adverse witnesses and advise counsel of any inconsistencies, errors, or falsehoods in their testimony.
Court’s Reasoning
The Court of Appeals emphasized that a defendant has a fundamental right to be present at any material stage of the trial. It cited precedent, including People v. Velasco and People v. Mullen, to support this principle. The court reasoned that a hearing where testimony is received qualifies as a material stage because it directly impacts the defendant’s ability to defend themselves. The court noted, “Proceedings where testimony is received are material stages of the trial because defendant’s presence is necessary so that he or she may confront adverse witnesses and advise counsel of any inconsistencies, errors or falsehoods in their testimony.”
The court distinguished the hearing from the witness’s subsequent testimony before the jury, stating, “At that stage of the trial, the court had already decided the evidence had probative value and would be received for the jury’s consideration.” Thus, the defendant’s presence at the later stage did not cure the error of their exclusion from the earlier hearing, where the admissibility of the evidence was being determined. The Court relied on the principle that a defendant’s absence from such hearings could have a substantial effect on their ability to defend, referencing Snyder v. Massachusetts.