People v. Tai, 73 N.Y.2d 989 (1989)
A defendant is entitled to a jury instruction on a lesser-included offense if there is a reasonable view of the evidence that would support a finding that the defendant committed the lesser offense but not the greater.
Summary
Defendant Tai was convicted of second-degree murder. At trial, defense counsel requested a jury instruction on lesser-included offenses, specifically first-degree manslaughter, but the request was denied. The Court of Appeals reversed the Appellate Division’s affirmance of the conviction, holding that the trial court erred in refusing to provide the requested instruction because a reasonable view of the evidence supported the possibility that the defendant committed manslaughter rather than murder. The Court emphasized that the entire evidence of the street melee must be considered when evaluating whether the lesser charge instruction should have been provided.
Facts
The incident began as a verbal dispute between the defendant and an individual named Razor at 9:00 p.m. The dispute escalated into a chase, with the defendant brandishing a knife while pursuing Razor and three of his friends. The chase culminated in a physical altercation involving multiple people. During the melee, the homicide victim intervened to assist the defendant. The defendant then stabbed the victim twice, resulting in the victim’s death.
Procedural History
The defendant was convicted of second-degree murder and related crimes in the trial court. The Appellate Division affirmed the judgment of conviction. A Justice of the Appellate Division granted leave to appeal to the Court of Appeals.
Issue(s)
Whether the trial court erred by refusing defense counsel’s request to instruct the jury on lesser-included offenses, specifically manslaughter in the first degree.
Holding
Yes, because a reasonable view of the evidence presented during the trial supported the possibility that the defendant committed the lesser offense of manslaughter in the first degree, rather than second-degree murder.
Court’s Reasoning
The Court of Appeals determined that the trial court erred in refusing to provide the requested jury instruction on the lesser-included offense of manslaughter in the first degree. The Court reasoned that, based on a review of the entire record evidence concerning the street melee, there was a reasonable basis for the jury to conclude that the defendant committed manslaughter rather than murder. The court stated that