People v. Knight, 87 N.Y.2d 891 (1995)

When a trial court provides written instructions to the jury, those instructions must present a complete and balanced representation of the applicable law, especially concerning defenses raised at trial; failure to do so constitutes reversible error.

Summary

Defendant was convicted of manslaughter, but the Court of Appeals reversed, holding that the trial court committed reversible error by providing the jury with an abbreviated written instruction on justification after giving a complete oral charge. The court reasoned that the incomplete written charge risked undue emphasis on certain aspects of the law while subordinating favorable defense arguments, particularly since the judge denigrated the oral charge in comparison to the written one. This was deemed inherently prejudicial and not subject to harmless error analysis.

Facts

The defendant was on trial for manslaughter. The sole defense raised at trial was justification. The trial court gave a complete oral charge to the jury regarding the defense of justification.

Procedural History

The trial court furnished the jury with a two-page document setting forth an abbreviated version of a portion of its oral charge, including certain principles of the justification defense, over the defendant’s objection. The Appellate Division affirmed the conviction. The Court of Appeals granted leave to appeal.

Issue(s)

Whether a trial court commits reversible error when, after giving a complete oral charge to the jury including the defense of justification, it furnishes the jury with a written document containing an abbreviated version of the justification defense over the defendant’s objection.

Holding

Yes, because the incomplete written charge risked undue emphasis on certain aspects of the law while subordinating favorable defense arguments; and because the trial judge exacerbated this risk by denigrating the oral charge in comparison to the “simpler” written one. This constitutes reversible error.

Court’s Reasoning

The Court of Appeals relied heavily on its prior decision in People v. Owens, 69 N.Y.2d 585 (1987), which held that it is improper for a trial court to distribute only certain portions of its charge in writing to the jury over defense counsel’s objection. The court reasoned that doing so creates a risk that the jury will perceive the writing as embodying the more important instructions, inviting greater attention to the principles that are repeated in writing than those simply recited orally.

The Court emphasized that while the trial court in this case did not omit entirely any reference to the defense of justification in the written submission, it failed to include the full explanation embodied in the oral charge, thereby “inviting the jury to place undue emphasis on those matters contained in the written submission, subordinating those portions of the charge—favorable to the defense—contained in the oral charge.”

The Court further noted that the trial judge here exacerbated the danger by denigrating the oral charge as a “detailed explanation” that he was “required to give,” and implicitly urging the jury to work instead with the written version, a “much shorter”, “condensed”, “abbreviated explanation of justification” in “simpler language” that would be available in the jury room. The court reiterated its stance from Owens that such error may not be considered harmless.

The practical effect of this ruling is that trial courts must be exceedingly careful when providing written materials to juries. If a court chooses to provide a written summary of the law, it must ensure that the summary is complete and does not unduly emphasize certain aspects of the law over others, especially when a specific defense is at issue. Any imbalance or perceived denigration of the full oral charge can lead to reversible error.