New York Law Review

Tag: People v. Thompson

  • People v. Thompson, 22 N.Y.3d 687 (2014): Limits on Prosecutorial Influence on Grand Jury Discretion

    People v. Thompson, 22 N.Y.3d 687 (2014)

    While prosecutors advise grand juries, they cannot use their influence to undermine the grand jury’s independent discretion to hear witnesses requested by the defendant, although not every misstep warrants dismissal of an indictment.

    Summary

    Thompson was convicted of second-degree murder. He appealed, arguing that the prosecutor committed misconduct before the grand jury by discouraging them from hearing a witness he requested. The New York Court of Appeals affirmed the conviction, holding that while the prosecutor’s actions were not ideal, they did not rise to the level of impairing the integrity of the grand jury proceedings because the grand jury ultimately exercised its discretion in the matter. The Court emphasized that the grand jury is an independent body and the prosecutor’s role as legal advisor does not give them the power to control the grand jury’s decisions, but requires a showing of pervasive misconduct to warrant dismissal of an indictment.

    Facts

    Thompson was arrested for the murder of Rasheem Williams. In a prior grand jury proceeding on weapons charges, a witness, Jane Doe, gave a description of the shooter somewhat consistent with Thompson, but stated she did not see the shooter’s face due to fear from anonymous threats. Subsequently, another witness, James Doe, came forward, identifying Thompson as the shooter. The People presented murder charges to a second grand jury. Thompson testified and requested the grand jury call Jane Doe as a witness, claiming she would exonerate him. The prosecutor questioned the relevance of Jane Doe’s testimony.

    Procedural History

    The grand jury indicted Thompson on murder and weapons charges. Thompson moved to dismiss the indictment, arguing prosecutorial misconduct. The Supreme Court denied the motion. Thompson was convicted at trial. He appealed, and the Appellate Division affirmed. The case then went to the New York Court of Appeals.

    Issue(s)

    1. Whether the prosecutor’s comments regarding the defendant’s requested witness impaired the integrity of the grand jury proceedings.

    Holding

    1. No, because the prosecutor’s comments, while not ideal, did not prevent the grand jury from exercising its independent discretion in deciding whether to hear from the witness, and the grand jury was not misled into thinking that they had no choice but to agree with the prosecutor.

    Court’s Reasoning

    The Court of Appeals recognized the importance of the grand jury as an independent body. It stated that under CPL 190.50, the grand jury has the power to subpoena witnesses, even those not called by the People. While the prosecutor is the legal advisor to the grand jury, due process requires fair dealing and candor. However, the Court emphasized that a grand jury proceeding is not a mini-trial, but an investigation to determine if sufficient evidence exists to accuse someone of a crime. Here, the prosecutors allowed Thompson to submit his request to call the witness directly to the grand jurors, and told the grand jurors they could vote to hear from the witness. The Court acknowledged the lead prosecutor forcefully contended that the witness’s testimony would be irrelevant. However, the lead prosecutor clarified that, despite her objections, the grand jurors had the right to call the witness based on their own belief regarding the relevance of the potential witness’s testimony. The Court pointed to the grand jurors’ assertive conduct as evidence that the prosecutors did not undermine the grand jurors’ independence. A grand juror repeatedly expressed skepticism regarding the prosecutor’s assertions and the grand jurors voted to hear from witnesses proffered by another defendant. The court held that the remedy of dismissing an indictment due to prosecutorial misconduct is an exceptional remedy, available only in rare cases, requiring a showing of pervasive bias and misconduct. Here, the Court found that the prosecutors did not commit pervasive misconduct, nor were they motivated by bias or a desire to deceive the grand jury. The Court distinguished this case from People v. Hill, 5 N.Y.3d 772 (2005), because the prosecutors did not hide the full extent of Thompson’s offer of proof, and the prosecutors’ conduct was justified by a concern for the safety of a prior witness. Thus, the Court affirmed the order of the Appellate Division.

  • People v. Thompson, 21 N.Y.3d 557 (2013): Ineffective Assistance of Counsel and Peremptory Challenges

    People v. Thompson, 21 N.Y.3d 557 (2013)

    A defense attorney’s failure to use a peremptory challenge to remove a prospective juror who had a long-standing friendship with the prosecuting attorney does not automatically constitute ineffective assistance of counsel, especially if the overall fairness of the trial was not demonstrably impaired.

    Summary

    The defendant was convicted of manslaughter after a trial where a juror was seated who had a 40-year friendship with the District Attorney. Defense counsel challenged the juror for cause, but the challenge was denied. Despite having peremptory challenges available, counsel did not use one to remove the juror. The New York Court of Appeals held that the defense counsel’s failure to use a peremptory challenge, while questionable, did not amount to ineffective assistance of counsel because the defendant failed to show that the fairness of the trial was impaired. The Court emphasized that a single error by otherwise competent counsel must be egregious and prejudicial to warrant reversal.

    Facts

    The defendant was charged with murder. During jury selection, a prospective juror, William Peters, disclosed that he had been friends with the District Attorney for over 40 years, knew his wife, and socialized with him occasionally. Peters stated that the friendship would not affect his ability to be a fair and impartial juror. Defense counsel questioned Peters, who stated he had known the District Attorney to be wrong before.

    Procedural History

    The defense challenged Peters for cause, which the trial court denied. The defense did not use a peremptory challenge to remove Peters, who then sat on the jury. The jury acquitted the defendant of second-degree murder but convicted him of manslaughter. The Appellate Division affirmed the conviction. The New York Court of Appeals granted leave to appeal.

    Issue(s)

    Whether defense counsel’s failure to exercise a peremptory challenge against a prospective juror who had a long-standing friendship with the prosecuting attorney constituted ineffective assistance of counsel, thus depriving the defendant of his constitutional right to a fair trial.

    Holding

    No, because the defendant failed to demonstrate that the fairness of the trial was impaired by the juror’s presence, and the attorney’s decision, while potentially questionable, did not constitute an egregious and prejudicial error that deprived the defendant of his constitutional right to counsel.

    Court’s Reasoning

    The Court of Appeals acknowledged that the defense counsel’s decision not to use a peremptory challenge was questionable, especially considering the potential for bias or the lost opportunity to preserve the for-cause challenge for appeal. However, the Court reasoned that defense counsel may have had strategic reasons for keeping Peters on the jury, such as believing Peters would be favorable to the defense or would bend over backwards to be fair. The Court emphasized that to succeed on an ineffective assistance of counsel claim based on a single error, the defendant must show that the error was so serious that it deprived him of his constitutional right to a fair trial. Citing People v. Turner, the Court stated that such error must be “a defense as clear-cut and completely dispositive as a statute of limitations.” Here, the Court held that the relationship between the juror and the prosecutor, while raising concerns, did not reach that level of egregiousness. While it might have been wiser for the trial judge to excuse Peters, the Court found it debatable whether the court committed reversible error. The Court highlighted the lack of evidence showing the juror’s presence prejudiced the defendant. Thus, the Court concluded that the defense counsel’s representation, taken as a whole, was not ineffective.

  • People v. Thompson, 90 N.Y.2d 615 (1997): Defendant’s Right to Be Present at All Material Stages of Trial

    People v. Thompson, 90 N.Y.2d 615 (1997)

    A defendant has a right to be present at all material stages of trial, including when evidence is received; however, unsupervised jury viewings of exhibits after their formal admission, but before deliberations, do not violate this right per se if proper admonishments are given.

    Summary

    The New York Court of Appeals addressed whether a defendant’s right to be present at all material stages of trial was violated when jurors were allowed to view evidentiary exhibits unsupervised after the exhibits had been formally admitted into evidence but before deliberations began. The Court held that while a defendant has a fundamental right to be present during the reception of evidence, the unsupervised viewing of exhibits in this case did not automatically warrant reversal, especially since the trial judge provided cautionary instructions. The dissent argued that the defendant’s right to be present extends to the time when the jury actually examines the exhibits, and the unsupervised viewing created a risk of prejudice and substantive irregularities.

    Facts

    During the trial, the judge permitted the jurors to examine exhibits during breaks and lunch periods, without the judge or counsel present. These exhibits had already been formally admitted into evidence. The judge provided the jury with general admonishments about their conduct during these viewings but was not present during the viewings themselves. The defendant was convicted, and the conviction was appealed based on the unsupervised jury viewings.

    Procedural History

    The defendant was convicted at trial. The defendant appealed, arguing the unsupervised jury viewings violated his right to be present at all material stages of trial. The appellate division affirmed the conviction. The New York Court of Appeals granted leave to appeal to consider the issue.

    Issue(s)

    Whether a defendant’s right to be present at all material stages of trial is violated when jurors are permitted to view evidentiary exhibits unsupervised after those exhibits have been formally admitted into evidence but before deliberations begin?

    Holding

    No, because while a defendant has the right to be present during the reception of evidence, unsupervised jury viewings of exhibits already admitted into evidence do not automatically warrant reversal, provided that the jury receives appropriate cautionary instructions.

    Court’s Reasoning

    The Court reasoned that the core concern is whether the defendant’s presence would have a substantial effect on his ability to defend against the charges. While the reception of evidence is a material stage of trial, the specific procedure employed by the trial court did not, in itself, compromise the defendant’s rights. The Court distinguished the act of formally admitting evidence from the act of jurors reviewing admitted evidence, finding the latter, under the circumstances, did not mandate the defendant’s presence. The Court emphasized that the trial judge gave cautionary instructions to the jury. The Court noted that the supervision of a judge is an important element of a jury trial, but determined that judicial presence isn’t required for every interaction with evidence, particularly when cautionary instructions have been given.

    The dissent argued that the defendant’s right to be present extends to the point when the jury actually examines the exhibits, not just when they are formally admitted. The dissent highlighted the potential for meaningful participation by the accused during the viewing of exhibits, as the defendant could observe juror reactions and suggest further lines of inquiry to counsel. The dissent also raised concerns about the informality of the procedure and the risk of substantive irregularities, such as some jurors viewing evidence while others did not. The dissent stated, “[T]he supervision of a Judge is an important and nonwaivable element of the right to a jury trial.”

  • People v. Thompson, 681 N.E.2d 616 (N.Y. 1997): Judge Substitution During Trial

    People v. Thompson, 681 N.E.2d 616 (N.Y. 1997)

    The substitution of a judge during a jury trial due to the original judge’s incapacitation does not automatically violate a defendant’s right to due process under the New York State Constitution, provided the substitute judge certifies familiarity with the trial record and the defendant suffers no undue prejudice.

    Summary

    Defendant was convicted of kidnapping, rape, sodomy, assault, and robbery. During the trial, the original judge became seriously ill and was replaced by another judge. The defendant moved for a mistrial, which was denied. The substitute judge certified familiarity with the record and the trial continued. The New York Court of Appeals affirmed the conviction, holding that substitution of a judge during a jury trial is permissible when the original judge is incapacitated, the substitute judge is familiar with the record, and the defendant suffers no prejudice. The Court declined to adopt a more stringent standard under the State Constitution than exists under the Federal Constitution.

    Facts

    The female complainant was abducted, sexually assaulted, and robbed by the defendant. During the 20-hour ordeal, she was able to briefly observe the defendant and her surroundings. She later identified the defendant in a lineup, and a search of his apartment uncovered evidence linking her to the scene.

    Procedural History

    The jury trial commenced in Supreme Court. Mid-trial, the original Justice was hospitalized. The case was reassigned to a new Justice. The defendant moved for a mistrial, which was denied. The Appellate Division affirmed the conviction. The New York Court of Appeals granted leave to appeal.

    Issue(s)

    Whether the substitution of the presiding judge during a jury trial, due to the original judge’s incapacitation, violated the defendant’s right to due process under the New York State Constitution.

    Holding

    No, because the substitute judge certified familiarity with the record of the proceedings, and the defendant failed to demonstrate any prejudice stemming from the substitution.

    Court’s Reasoning

    The Court of Appeals acknowledged that the right to a jury trial is guaranteed by both the Federal and State Constitutions. While early New York cases suggested that judge substitution was impermissible, the Court noted the evolving standards at the federal level, particularly the adoption of Federal Rule of Criminal Procedure 25(a), which permits substitution under specific circumstances. The court stated, “[T]here is no State constitutional mandate for a jury trial before the same Judge from start to finish.” The Court balanced the interests of the parties, the adequacy of the procedures, and the government’s stake in the outcome, concluding that midtrial substitution does not rise to a per se constitutional violation. The Court held that “generally, a Judge may be substituted for another if the original Judge becomes incapacitated during a jury trial, as long as the substitute indicates on the record the requisite familiarity with the proceedings and no undue prejudice occurs to the defendant or the People.” The court found the defendant demonstrated no prejudice.

  • People v. Thompson, 83 N.Y.2d 477 (1994): Cruel and Unusual Punishment and Mandatory Minimum Sentencing

    83 N.Y.2d 477 (1994)

    Mandatory minimum sentences for drug offenses are constitutional unless they are grossly disproportionate to the crime, considering the gravity of the offense and the character of the offender.

    Summary

    Angela Thompson, a 17-year-old, was convicted of selling cocaine and sentenced to 8 years to life. The trial court found that the mandatory minimum sentence of 15 years to life would be cruel and unusual punishment. The Appellate Division affirmed. The Court of Appeals reversed, holding that the mandatory minimum sentence did not constitute cruel and unusual punishment in this case because her actions indicated a high degree of culpability and the legislature’s sentencing decision was not irrationally severe.

    Facts

    Thompson, 17, sold 214 vials of cocaine to an undercover officer for $2,000 in a known drug location. The sale exceeded the threshold for a class A-I felony by a small amount (2.13 grams). She promised to “take care of” the officer the next time he came. Thompson’s uncle, Norman Little, was a major drug dealer, and Thompson was employed in his operation.

    Procedural History

    Thompson was indicted and convicted of a class A-I felony in Supreme Court, New York County. The trial court sentenced her to 8 years to life, finding the mandatory minimum of 15 years to life would be cruel and unusual punishment. The Appellate Division affirmed. The People appealed to the New York Court of Appeals.

    Issue(s)

    Whether imposing the mandatory minimum sentence of 15 years to life for a class A-I felony conviction on Thompson constitutes cruel and unusual punishment under the Eighth Amendment of the U.S. Constitution and Article I, Section 5 of the New York Constitution.

    Holding

    No, because the mandatory minimum sentence is not grossly disproportionate to the crime and does not constitute cruel and unusual punishment, considering the gravity of the offense and the character of the offender.

    Court’s Reasoning

    The Court relied on People v. Broadie, which upheld the facial and as-applied validity of mandatory sentences for drug offenses, while acknowledging rare cases where it might be unconstitutionally applied. The Court applied a gross disproportionality standard, considering the gravity of the offense and the character of the offender. Drug dealing is a grave offense because of its harm to society. The court considered that “drug-related crimes may be much more prevalent…requiring greater isolation and deterrence” (People v. Broadie, 37 N.Y.2d at 116). Thompson’s conduct showed significant culpability; she made a direct sale, haggled over the quantity, and promised future service, showing she was not an “accidental offender.” Although Thompson was young, the legislature consciously extended the A-I felony mandatory minimums to youths in her age category. The court distinguished Thompson’s direct sale of a significant quantity of drugs from the defendant in People v. Jones, who was merely a low-level “millhand.” The court stated that the legislature could rationally determine that teenage drug dealers pose a serious threat to society. The dissent argued for a more nuanced approach considering factors like the defendant’s role in the operation, her age, and the disparity between her sentence and that of her uncle. Ultimately, the majority deferred to the legislature’s judgment, holding that reform of sentencing policy should be legislative, not judicial.

  • People v. Thompson, 72 N.Y.2d 412 (1988): Forcible Compulsion and the Victim’s State of Mind

    People v. Thompson, 72 N.Y.2d 412 (1988)

    The determination of whether a threat constitutes forcible compulsion in a sex offense case depends on the state of mind produced in the victim by the defendant’s conduct, specifically whether the victim fears immediate death or serious physical injury, regardless of the defendant’s actual ability to carry out the threat.

    Summary

    Thompson was convicted of first-degree sodomy. The Appellate Division reversed, arguing insufficient evidence of forcible compulsion because the threats were made across jail bars. The Court of Appeals reversed, holding that the focus should be on the victim’s fear of immediate harm created by the threats, not the defendant’s actual ability to carry them out. The court emphasized that the relevant question is whether a jury could reasonably infer that the threats placed the victim in fear of immediate death or serious physical injury. The case was remitted to the Appellate Division for factual review and to address other unresolved issues.

    Facts

    The victim, a 16-year-old inmate, was housed in the juvenile tier of the Albany County jail. The defendant, a 35-year-old inmate from the adult tier, gained access to the juvenile tier’s catwalk. Separated by bars, the defendant demanded oral sex from the victim. When the victim refused, the defendant threatened to have others assault him, stating that the victim could be beaten up anywhere, even on the tier, and that he would ensure the victim had a rough time in jail. Another inmate testified that he heard the defendant say, “[I]f you don’t give me no piece of ass I’ll kick your ass.” The victim then complied with the defendant’s demands.

    Procedural History

    The defendant was convicted of two counts of first-degree sodomy in the trial court. The Appellate Division reversed the conviction, finding insufficient evidence of forcible compulsion. The People appealed to the New York Court of Appeals.

    Issue(s)

    1. Whether the defendant’s threats, made from behind jail bars, constituted forcible compulsion as defined by Penal Law § 130.00(8).
    2. Whether the focus of determining forcible compulsion should be on the defendant’s capability to carry out the threats, or on the victim’s state of mind and fear of immediate harm.

    Holding

    1. Yes, because the relevant inquiry is not whether the defendant was capable of carrying out the threats, but whether the jury could reasonably infer that those threats placed the victim in fear of immediate death or serious physical injury.
    2. The focus should be on the victim’s state of mind and fear of immediate harm, because the sine qua non for criminal liability for sex offenses is lack of consent, resulting from either forcible compulsion or incapacity to consent.

    Court’s Reasoning

    The Court of Appeals reasoned that the Appellate Division erred by focusing on the defendant’s immediate ability to carry out his threats. Instead, the court emphasized that the proper focus is on the victim’s state of mind and the fear induced by the defendant’s conduct. Citing People v. Coleman, 42 NY2d 500, 505, the court stated that the inquiry is “not what the defendant would or could have done, but rather what the victim, observing [the defendant’s] conduct, feared [he] would or might do if [the victim] did not comply with [his] demands.” The court noted that the impossibility or improbability of the threats may be relevant to whether the victim was actually in fear, but it does not transform submission into consent. The court stated, quoting the Model Penal Code, “one who takes advantage of [a victim’s] unreasonable fears of violence should not escape punishment any more than a swindler who cheats gullible people by false statements which they should have found incredible.” The court found that the defendant’s threats, viewed in the context of the jail environment and the disparity in age and size between the defendant and the victim, provided a sufficient basis for the jury’s conclusion that the victim feared immediate harm. The court also pointed out that the defendant’s threat that the victim could “get beat up anywhere, it could even be somebody on the tier” implied an immediate threat, as inmates had access to the victim within the tier. The court ultimately reversed the Appellate Division’s order and remitted the case for further proceedings.

  • People v. Thompson, 60 N.Y.2d 513 (1983): Appellate Division’s Power to Reduce Sentences

    People v. Thompson, 60 N.Y.2d 513 (1983)

    The Appellate Division has the statutory authority to reduce a sentence it deems unduly harsh or severe in the interest of justice, even if the sentence was part of a plea agreement, and is not required to grant the prosecution an opportunity to withdraw from the plea agreement when it exercises this authority.

    Summary

    Thompson pleaded guilty to first-degree manslaughter and received a sentence of 8 1/3 to 25 years. The Appellate Division initially reduced the sentence to 3 1/3 to 10 years as excessive. Relying on People v. Farrar, the Appellate Division amended its order to allow the prosecution to withdraw its consent to the plea. The Court of Appeals held that the Appellate Division has broad statutory authority to reduce sentences it deems unduly harsh and is not bound by the Farrar rule, which applies only to trial courts. The Court reinstated the Appellate Division’s initial sentence reduction.

    Facts

    In July 1978, 17-year-old Thompson shot and killed another youth in Brooklyn. The victim and others confronted Thompson, accusing him of stealing a bicycle. Thompson claimed self-defense, alleging the victim had previously hit him with a car, leading him to borrow a gun for protection. Thompson had no prior criminal record. He was indicted for second-degree murder and first-degree weapon possession.

    Procedural History

    Thompson was indicted and initially went to trial. After jury selection, he pleaded guilty to first-degree manslaughter in exchange for a stipulated sentence of 8 1/3 to 25 years. The trial court imposed the agreed-upon sentence, denying youthful offender treatment. Thompson appealed, arguing the sentence was unduly harsh. The Appellate Division initially reduced the sentence to 3 1/3 to 10 years in the interest of justice. On the People’s motion, the Appellate Division amended its order to allow the prosecution to withdraw its consent to the plea, consistent with People v. Farrar. Both sides appealed to the Court of Appeals.

    Issue(s)

    Whether the Appellate Division, when finding a sentence excessive, is required to afford the prosecution an opportunity to withdraw its consent to the plea agreement, as mandated for trial courts in People v. Farrar.

    Holding

    No, because the Appellate Division’s power to review and reduce sentences is governed by statutes that do not require affording the prosecution an opportunity to withdraw from the plea agreement. The Farrar rule applies only to trial courts.

    Court’s Reasoning

    The Court of Appeals distinguished the Appellate Division’s power from that of the trial court, noting that the Farrar decision was based on statutes applicable only at the trial court level (CPL 220.10). The Appellate Division’s power to review sentences stems from CPL 450.10(2), 470.15(6)(b), and 470.20(6), which authorize the court to modify sentences that are “unduly harsh or severe” in the interest of justice. The court emphasized that CPL 470.20(6) mandates that the Appellate Division “must itself impose some legally authorized lesser sentence” when modifying a judgment on the grounds of excessive harshness. The Court stated, “Thus the Appellate Division was not bound, as it assumed, to afford the People the option of withdrawing their consent to the plea once it concluded in the exercise of its discretion that the sentence imposed was excessive.” The Court highlighted the long-recognized power of the Appellate Division to reduce sentences, originally an inherent power and later codified. The Court also rejected the argument that Thompson forfeited his right to appeal his sentence by pleading guilty, stating, “Although the scope of appeal in a criminal case after a guilty plea is narrowly limited, one of the questions reviewable by an Appellate Division is the severity of sentence”. Finally, the court reiterated that whether a sentence is harsh or severe is a discretionary matter not reviewable by the Court of Appeals.

  • People v. Thompson, 27 N.Y.2d 61 (1970): Enforcing the Statutory Sequence of Peremptory Challenges

    People v. Thompson, 27 N.Y.2d 61 (1970)

    The statutory requirement in the Code of Criminal Procedure that the prosecution must exercise peremptory challenges before the defendant is a substantial right, and a violation of this sequence constitutes reversible error.

    Summary

    This case addresses whether a trial court’s allowance of the People’s peremptory challenge after the defendant had already exercised their challenges and accepted the juror constitutes reversible error. The Court of Appeals reversed the conviction, reaffirming its prior holdings in People v. McQuade and People v. Grieco. The court emphasized the importance of adhering to the statutory sequence of peremptory challenges, as outlined in Section 385 of the Code of Criminal Procedure, deeming it a substantial right of the accused, not a mere technicality.

    Facts

    During jury selection, after both the People and the defendant had used some of their peremptory challenges, the prosecution was allowed, over the defendant’s objection, to exercise a peremptory challenge against a juror who had previously been unchallenged. The trial court then excused the juror.

    Procedural History

    The defendant was convicted. The Court of Appeals reviewed the trial court’s decision regarding the jury selection process.

    Issue(s)

    Whether the trial court committed reversible error by allowing the People to exercise a peremptory challenge to a juror after the defendant had already exercised their peremptory challenges and indicated satisfaction with the juror, violating the sequence prescribed by Section 385 of the Code of Criminal Procedure.

    Holding

    Yes, because the sequence of challenges is a substantial right, and violating the statutory procedure constitutes reversible error, consistent with precedent.

    Court’s Reasoning

    The court relied heavily on the precedent set by People v. McQuade, which established that the order of peremptory challenges is a substantial right, not a mere technicality that can be disregarded under Section 542 of the Code of Criminal Procedure. The court acknowledged that while the error might seem inconsequential in many cases, the strict interpretation of Section 385 had been consistently followed since McQuade. The court also cited People v. Grieco, where a similar violation was deemed reversible error. The court acknowledged People v. Williams as a seeming aberration where the error was deemed harmless because the defendant had unused challenges. However, the court reaffirmed the consistent adherence to the McQuade rule, stating, “when the articulated statements of the court since McQuade are placed in full context it is to be seen that the rule of that case has been consistently avowed and followed, [and] no strong policy reason suggests departure now from a rule which has thus been firmly reiterated.” The court concluded that allowing the prosecution to challenge a juror after the defense had already accepted them violated the defendant’s substantial rights, warranting a new trial. The court emphasized the importance of adhering to established legal procedures, even when the practical impact appears minimal, to safeguard the integrity of the trial process.