People v. Padgett, 60 N.Y.2d 142 (1983)

A defendant is entitled to a jury instruction on the justification defense even when they deny intending to cause the property damage that forms the basis of a criminal mischief charge, provided there’s a reasonable view of the evidence that the damage occurred as an emergency measure to avoid imminent injury.

Summary

Padgett was convicted of criminal mischief for breaking a bar’s emergency exit door. He argued he broke the door while trying to escape an altercation with the bar owner and requested a justification defense instruction, which the trial court denied. The Court of Appeals reversed, holding that a justification charge should be given if any reasonable view of the evidence supports it, even if the defendant claims the damage was unintentional. The Court reasoned that Padgett’s testimony, indicating he broke the door to avoid a perceived attack, warranted the instruction.

Facts

Defendant Padgett and his companions were in a bar. An incident occurred where the emergency exit door alarm was triggered. The bar owner testified that Padgett laughed and triggered the alarm again, then punched the door, shattering the glass. Padgett testified that after the alarm went off, the bar owner threatened him, and he, fearing an attack, pushed the emergency door hard to exit, unintentionally breaking the glass. An altercation ensued.

Procedural History

Padgett was convicted of criminal mischief in the trial court. The Appellate Term affirmed the conviction. One Justice dissented, arguing that Padgett’s testimony supported a justification defense. The New York Court of Appeals reversed the Appellate Term’s order, ordering a new trial.

Issue(s)

Whether a defendant is entitled to a jury instruction on the defense of justification for a criminal mischief charge when the defendant claims that the property damage was unintentional, but occurred while attempting to avoid an imminent private injury.

Holding

Yes, because if there is any reasonable view of the evidence under which the fact finder might have decided that the defendant’s actions were justified, the failure to charge the defense constitutes reversible error.

Court’s Reasoning

The Court relied on Penal Law § 35.05(2), which states that conduct that would otherwise be an offense is justifiable when it “is necessary as an emergency measure to avoid an imminent * * * private injury which is about to occur by reason of a situation occasioned or developed through no fault of the actor.” The court emphasized that the record must be viewed most favorably to the defendant when considering the adequacy of the jury charge, citing People v. Watts, 57 N.Y.2d 299, 301. Even though Padgett claimed he didn’t intend to break the glass, his testimony suggested he broke it while trying to avoid an attack by the bar owner. The court cited People v. Huntley, 87 A.D.2d 488, which held that a defendant’s claim of thwarting an attempted armed robbery was sufficient to require presenting the justification issue to the jury, even if the defendant never admitted intending to stab the victim. The court reasoned that the inconsistency between claiming unintentional damage and a justification defense shouldn’t deprive the defendant of the requested charge. The court stated, “Defendant’s explanation indicates that he engaged in conduct in avoidance of the perceived attack. That conduct forms the basis for a charge of criminal mischief. The fact that defendant never admitted that he intended to cause the resulting property damage should not disentitle him to a charge that his conduct might not have been criminal under the circumstances.”