People v. Colon, 77 N.Y.2d 95 (1990)
Evidence of a defendant’s involvement in large-scale drug sales is inadmissible in a trial for simple drug possession if its prejudicial effect outweighs its probative value.
Summary
Defendant Colon was convicted of criminal possession of a controlled substance in the third degree. At trial, the prosecution introduced extensive evidence linking Colon to a large-scale drug selling enterprise. The defense argued this evidence was unduly prejudicial. The Court of Appeals affirmed the conviction, finding the evidence was confirmatory of testimony already introduced by the defense. However, the dissenting judge argued the prosecution’s evidence went far beyond the defense’s and improperly portrayed Colon as an active participant in drug trafficking, thus warranting a new trial. This case highlights the importance of balancing probative value against prejudicial effect when admitting evidence of uncharged crimes.
Facts
Colon was charged with a single count of criminal possession of a controlled substance in the third degree. At trial, the prosecution presented significant testimony linking Colon to a large-scale drug operation. The defense objected to the introduction of this evidence, arguing that it was more prejudicial than probative. Specific details of the possessed substance or the nature of the larger drug operation were not detailed in the dissent.
Procedural History
The defendant was convicted at trial. The Appellate Division affirmed the conviction, finding that the evidence was confirmatory of testimony already introduced by the defense. The case was appealed to the New York Court of Appeals. The Court of Appeals affirmed the Appellate Division’s order.
Issue(s)
Whether the trial court erred in admitting extensive testimony linking the defendant to a large-scale drug selling enterprise in a trial for simple drug possession, where the defense argues such evidence is unduly prejudicial and deprives the defendant of a fair trial.
Holding
No, because the evidence presented by the prosecution was confirmatory of testimony already introduced by the defense, and thus its admission was not unduly prejudicial.
Court’s Reasoning
The majority of the Court of Appeals agreed with the Appellate Division’s finding that the evidence presented by the prosecution was “confirmatory” of testimony already introduced by defense counsel. The dissent argued that the prosecution’s evidence went far beyond that brought out by the defense and improperly created the impression that the defendant was an active participant in an ongoing drug trafficking operation. The dissent cited People v. Alvino, 71 NY2d 233; People v. Crandall, 67 NY2d 111; and People v. Molineux, 168 NY 264, as precedent for the principle that the introduction of highly prejudicial evidence can deprive a defendant of a fair trial. The key point of disagreement was whether the prosecution’s evidence merely confirmed the defense’s evidence or whether it introduced new, prejudicial information about Colon’s involvement in a large-scale drug enterprise. This case turns on the application of the rule that evidence of uncharged crimes is inadmissible if its probative value is outweighed by its prejudicial effect.