People v. Taylor, 83 N.Y.2d 837 (1994)
The defense of infancy against underlying charges does not automatically divest a court of jurisdiction over a subsequent bail jumping charge, particularly when the defendant misrepresented their age to the court.
Summary
Defendant Taylor, initially indicted for drug possession, pled guilty but misrepresented his age to the court. After being released pending sentencing, he failed to appear, leading to a bail jumping charge. The initial guilty plea was later withdrawn upon discovery of Taylor’s actual age (under 16). Despite this, he pled guilty to bail jumping. The New York Court of Appeals affirmed the bail jumping conviction, holding that the infancy defense against the underlying charges did not divest the court of jurisdiction over the bail jumping charge, especially considering Taylor’s initial misrepresentation to the court.
Facts
The defendant was indicted on drug possession charges.
He misrepresented his name and age (claiming to be 19) to the trial court.
He was released pending sentencing but failed to appear.
A bench warrant was issued for his arrest.
He was over 16 at the time he failed to appear for sentencing.
His guilty plea to the drug charge was withdrawn after his birth certificate revealed he was under 16 when the alleged possession occurred.
Procedural History
Defendant was indicted on drug possession charges and pleaded guilty.
He was then charged with bail jumping in the first degree after failing to appear for sentencing.
He withdrew his initial guilty plea to the drug charges.
He pleaded guilty to bail jumping in the first degree.
The Appellate Division affirmed the bail jumping conviction.
A dissenting Justice at the Appellate Division granted permission to appeal to the Court of Appeals.
Issue(s)
Whether the trial court was divested of jurisdiction over the bail jumping charge once the defense of infancy was raised regarding the predicate criminal charges.
Holding
No, because the infancy defense is an ordinary defense that must be raised by the defendant, and the defendant misrepresented his age to the court. The court had effective jurisdiction over him when he committed bail jumping.
Court’s Reasoning
The Court reasoned that infancy is an ordinary defense that must be raised by the defendant (Penal Law § 30.00 [3]). The defendant did not raise the defense initially and, in fact, misrepresented his age. The Court emphasized that the status of pending felony charges does not automatically nullify criminal liability for bail jumping, citing People v. Eiffel, 81 NY2d 480, 483. The Court considered the theoretical and practical effect of infancy on the criminal proceedings. The defendant’s misrepresentation of his age was a key factor in the Court’s decision, suggesting that he should not benefit from his deceit. The Court’s rationale implies a policy consideration against allowing defendants to manipulate the system by initially concealing their age and then claiming infancy to escape subsequent charges related to their failure to appear. There were no dissenting or concurring opinions noted.