New York Law Review

Tag: People v. Wilson

  • People v. Wilson, 4 N.Y.3d 777 (2005): Independent Basis Required for In-Court Identification After Suggestive Lineup

    4 N.Y.3d 777 (2005)

    When a pretrial lineup identification is deemed unduly suggestive, an in-court identification by the same witness is inadmissible unless the prosecution establishes an independent basis for the in-court identification, untainted by the suggestive lineup.

    Summary

    Wilson was convicted based on an eyewitness identification. The eyewitness identified Wilson in a lineup shortly after viewing Wilson’s photograph shown to him by a police officer. Wilson moved to suppress the lineup and any in-court identification. The trial court denied the motion, finding the lineup was not tainted. The appellate court reversed, finding the lineup unduly suggestive. However, the appellate court upheld the conviction, concluding there was an independent basis for the in-court identification. The Court of Appeals reversed, holding that the trial court had not actually made a finding of an independent basis, and remanded for a hearing on whether such a basis existed.

    Facts

    An eyewitness identified Wilson in a pretrial lineup.
    Prior to the lineup, a police officer showed the eyewitness a photograph of Wilson.
    Wilson moved to suppress the lineup identification and any potential in-court identification.
    The trial court denied the motion, finding the lineup untainted by the photo viewing.

    Procedural History

    The trial court convicted Wilson.
    The Appellate Division reversed the trial court’s finding that the lineup was not unduly suggestive but affirmed the conviction, stating that the trial court correctly found an independent basis for the in-court identification.
    Wilson appealed to the New York Court of Appeals.

    Issue(s)

    Whether an in-court identification is admissible when the pretrial lineup identification is deemed unduly suggestive and the trial court has not made an explicit finding regarding an independent source for the in-court identification.

    Holding

    No, because the trial court did not take the additional step of determining whether an independent source existed for the eyewitness’s in-court identification, the Appellate Division erred in concluding the trial court had “correctly found” that the eyewitness had an independent source for his in-court identification testimony.

    Court’s Reasoning

    The Court of Appeals reasoned that because the trial court never explicitly determined whether an independent source existed for the in-court identification, the Appellate Division erred in concluding that the trial court had “correctly found” such a basis.
    The Court emphasized that the Appellate Division could make a de novo independent source determination based on evidence from the suppression hearing but that the inquiry in this case was too truncated to allow for such a determination. The Court noted, “Because Supreme Court never took the additional step of determining whether an independent source existed for the eyewitness’s in-court identification, Supreme Court cannot be said to have ruled “correctly” when it never ruled at all.”
    The Court reiterated the importance of the prosecution presenting independent source evidence at a Wade hearing to avoid the risk of completely renewed proceedings, quoting People v. Burts, 78 N.Y.2d 20, 25 (1991) that, in light of the “risk for completely renewed proceedings” whenever a pretrial identification is challenged, the People are generally well-advised to come forward with any independent source evidence at a
    Wade hearing so that the suppression court may, where appropriate, rule in the alternative.
    This demonstrates a practical consideration for prosecutors to present all available evidence during the initial suppression hearing.
    The remedy was to reverse the conviction and remand the case to the Supreme Court for an independent source hearing prior to retrial.

  • People v. Wilson, 89 N.Y.2d 754 (1997): Right to Counsel at Investigatory Lineup

    People v. Wilson, 89 N.Y.2d 754 (1997)

    Once a suspect is represented by counsel, even on an unrelated charge, police cannot conduct an investigatory lineup without making reasonable efforts to notify and secure the attorney’s presence, absent exigent circumstances.

    Summary

    Eric Wilson, arrested on Brooklyn charges, was identified in a lineup as the perpetrator of a Queens homicide. Wilson’s attorney on the Brooklyn charges informed Queens detectives that he also represented Wilson on the Queens matter and that no questioning or lineups should occur without him. Despite this, police conducted a lineup without notifying the attorney, and Wilson was identified. The New York Court of Appeals held that because Wilson was represented by counsel, the lineup conducted without notifying counsel violated his right to counsel, requiring suppression of the identification. The Court emphasized the importance of affording a defendant’s attorney the opportunity to be present at critical stages of the investigation.

    Facts

    Defendant Eric Wilson was arrested on Brooklyn charges of criminal possession of a stolen vehicle and a weapon. The weapon was linked to a Queens homicide. An eyewitness identified Wilson’s photo as being involved in the Queens shooting. Wilson’s attorney, Norman Berle, representing him on the Brooklyn charges, informed Queens detectives that he also represented Wilson regarding the Queens matter and that no questioning or lineups should occur without his presence. The Brooklyn charges were dismissed, and Queens detectives took Wilson into custody. Advised of his Miranda rights, Wilson waived them and denied knowledge of the homicide. A lineup was conducted without notifying Berle, and Wilson was identified as the shooter.

    Procedural History

    The Supreme Court, Queens County, denied Wilson’s motion to suppress the lineup identification, finding that the attorney-client relationship terminated with the dismissal of the Brooklyn charges. Wilson was convicted of murder and other charges. The Appellate Division reversed, granting the motion to suppress and ordering a new trial, allowing the People to establish an independent source for the in-court identification. The Court of Appeals granted permission to appeal and affirmed the Appellate Division’s order.

    Issue(s)

    Whether an investigatory lineup conducted without notifying a suspect’s attorney, after the attorney informed police of their representation and requested their presence at any questioning or lineups, violates the suspect’s right to counsel.

    Holding

    Yes, because once a suspect is actually represented by counsel, a waiver of the right to counsel without the attorney present is ineffective, and the police are obligated to make reasonable efforts to notify counsel of an impending lineup, absent exigent circumstances.

    Court’s Reasoning

    The Court of Appeals relied on the principle that while a suspect has no constitutional right to counsel at a pre-indictment lineup, if a suspect already has counsel, that attorney may not be excluded from the lineup proceedings. The Court found that attorney Berle’s notification to the Queens detectives that he represented Wilson on the Queens matter created a duty for the police to notify Berle of the lineup. The Court cited People v. LaClere, 76 N.Y.2d 670 (1990), emphasizing that the police took the risk that the evidence would be suppressed by conducting the lineup without notice to counsel. The Court also noted that no exigent circumstances justified proceeding without counsel. The Court reasoned that once an attorney-client relationship is established and communicated to law enforcement, the police cannot disregard the attorney’s request to be present. Allowing a lineup without notifying known counsel undermines the protections afforded by the right to counsel. The court emphasized, “In conducting the lineup in these circumstances, without some notice or other legally recognized excusal of counsel’s presence, the police took the risk that the adduced evidence would not be allowed” (People v. LaClere, supra, at 672).

  • People v. Wilson, 86 N.Y.2d 753 (1995): Adequacy of Readiness Statements for Speedy Trial

    People v. Wilson, 86 N.Y.2d 753 (1995)

    A statement of readiness for trial is sufficient for speedy trial purposes under CPL 30.30(1)(a) if the prosecution communicates its readiness on the record and is, in fact, ready to proceed at that time.

    Summary

    The defendant appealed his conviction, arguing a violation of his speedy trial rights under CPL 30.30(1)(a). The Appellate Division had previously reversed the initial conviction and ordered a new trial. The Court of Appeals affirmed the conviction, holding that the prosecution’s statement of readiness, made within six months of the Appellate Division’s reversal, satisfied the requirements of CPL 30.30(1)(a). The Court clarified that a valid statement of readiness must be communicated on the record and reflect actual readiness, not merely a prediction of future readiness. Here, the prosecution secured the complainant’s cooperation, possessed a valid accusatory instrument, and had produced the defendant.

    Facts

    The defendant was originally convicted, but the Appellate Division reversed this conviction and remanded for a new trial. On March 22, 1990, following the reversal, the prosecution stated, “we have been in contact with the victim. Our intentions are to go forward.” The defendant subsequently argued that the People violated his right to a speedy trial by not being ready within six months as required by CPL 30.30(1)(a).

    Procedural History

    1. The defendant was initially convicted, but the Appellate Division reversed and remanded for a new trial.
    2. On the defendant’s second appeal, the Appellate Division remitted the case to County Court for a CPL 30.30 hearing.
    3. After the hearing, the Appellate Division upheld the conviction.
    4. The Court of Appeals affirmed the Appellate Division’s decision.

    Issue(s)

    Whether the prosecution’s statement, “we have been in contact with the victim. Our intentions are to go forward,” was a sufficient indication of readiness to satisfy the requirements of CPL 30.30(1)(a) for speedy trial purposes.

    Holding

    Yes, because the prosecution communicated their readiness on the record within six months of the Appellate Division’s reversal of the initial conviction, and possessed the ability to proceed with trial at that time.

    Court’s Reasoning

    The Court of Appeals applied CPL 30.30(1)(a), which requires the People to be ready for trial within six months of the commencement of a criminal action. In this case, the relevant date for calculating the six-month period was the date of the Appellate Division’s reversal of the defendant’s first conviction. The court relied on its prior decision in People v. Kendzia, 64 N.Y.2d 331, which established a two-pronged test for a valid statement of readiness: (1) the People must communicate their state of readiness on the record, and (2) the People must, in fact, be ready to proceed when they proclaim readiness.

    The Court found that the first element of Kendzia was satisfied by the prosecution’s on-the-record statement to the court. As to the second element, the Court emphasized that CPL 30.30 requires actual readiness, “and not a prediction or expectation of future readiness.” The court found that the People met this standard because they had secured the complainant’s cooperation for retrial, possessed a valid accusatory instrument, and had produced the defendant. The statement was therefore deemed a valid declaration of readiness, and the defendant’s speedy trial rights were not violated. The Court distinguished the facts from situations where the prosecution merely expresses a hope or expectation of future readiness, emphasizing the need for the prosecution to have taken concrete steps demonstrating their preparedness to proceed to trial. The Court agreed with the prior courts’ determination that the statement sufficiently indicated the People’s readiness for trial.

  • People v. Wilson, 64 N.Y.2d 634 (1984): The Marital Privilege and Missing Witness Inference

    People v. Wilson, 64 N.Y.2d 634 (1984)

    The marital privilege does not extend to observations of a spouse’s presence or absence unless those observations constitute a confidential communication made solely due to the marital relationship; furthermore, a missing witness charge is appropriate when a party fails to call an available witness, such as a spouse, who could support their alibi.

    Summary

    Wilson was convicted of a crime, and on appeal, he argued that the trial court erred in giving a missing witness charge regarding his wife, who did not testify to support his alibi. He also claimed that the charge violated his marital privilege and that his lineup identification was unduly suggestive. The New York Court of Appeals affirmed the Appellate Division’s order, holding that the missing witness charge was proper because the wife’s testimony would be favorable and not trivial. The court further clarified that the marital privilege does not automatically extend to observations of a spouse’s presence or absence unless those observations are confidential communications arising solely from the marital relationship. The lineup issue was not reviewable because it was a factual finding affirmed by the Appellate Division.

    Facts

    The defendant, Wilson, presented an alibi defense at trial, implying he was at home with his wife at the time of the crime. However, he did not call his wife to testify and support his alibi. The prosecution requested, and the trial court gave, a “missing witness” charge, allowing the jury to infer that the wife’s testimony would not have supported Wilson’s alibi. Wilson objected, asserting marital privilege.

    Procedural History

    The trial court convicted Wilson. The Appellate Division affirmed the conviction. Wilson appealed to the New York Court of Appeals, arguing that the missing witness charge was improper and violated his marital privilege. The Court of Appeals affirmed the Appellate Division’s order.

    Issue(s)

    1. Whether the trial court erred in giving a missing witness charge when the defendant failed to call his wife to support his alibi.
    2. Whether the missing witness charge violated the defendant’s marital privilege.

    Holding

    1. Yes, the trial court did not err in giving the missing witness charge because the wife was an available witness whose testimony would likely be favorable to the defendant and not trivial or cumulative.
    2. No, the missing witness charge did not violate the defendant’s marital privilege because the mere fact of his presence or absence from his apartment was not a confidential communication arising solely from the marital relationship.

    Court’s Reasoning

    The Court of Appeals reasoned that the missing witness charge was appropriate because Wilson presented an alibi, and his wife was an available witness who could have supported that alibi. Because she was not called, the jury could infer that her testimony would not have been favorable to Wilson. The court cited People v. Rodriquez, 38 NY2d 95, in support of this holding.

    Regarding the marital privilege, the court clarified that not all interactions between spouses are privileged. The privilege only applies to confidential communications that would not have occurred but for the marital relationship. The court cited People v. Melski, 10 NY2d 78, 80, stating, “The privilege is ‘designed to protect not all the daily and ordinary exchanges between the spouses, but merely those which would not have been made but for the absolute confidence in, and induced by, the marital relationship.’” The court found that Wilson’s mere presence or absence from his apartment was not such a communication. The court emphasized that acts, as well as words, can constitute communications, but only if they are confidential, citing People v. Daghita, 299 NY 194.

    The court distinguished between ordinary observations and confidential communications, highlighting the importance of confidentiality in invoking the marital privilege. The ruling emphasizes that the marital privilege is not a blanket protection against spousal testimony, but rather a shield for genuinely confidential exchanges rooted in the marital bond.

  • People v. Wilson, 57 N.Y.2d 786 (1982): Attenuation Doctrine and Admissibility of Evidence After Illegal Detention

    People v. Wilson, 57 N.Y.2d 786 (1982)

    Evidence obtained following an illegal detention is admissible if the taint from the initial illegality is sufficiently attenuated by intervening events and investigation, breaking the causal chain between the unlawful conduct and the acquisition of the evidence.

    Summary

    The New York Court of Appeals addressed whether identifications and statements obtained after an illegal detention should be suppressed as “fruits of the poisonous tree.” The court held that even though the initial detention was unlawful for lacking probable cause, the subsequent lineup identification and statements were admissible because the taint of the illegal detention was attenuated by the intervening time and the continued independent investigation by the Transit Authority police. The police obtained the defendant’s name, address, and photograph during the illegal detention, but this was considered basic identification information. A ten-day interval and further investigation, including informing the defendant of his rights before the lineup, sufficiently purged the taint of the initial illegality.

    Facts

    Transit Authority police stopped the defendant based on reasonable suspicion, but the suppression court later determined they lacked probable cause for the detention. During the illegal detention, the police obtained the defendant’s name, address, and photograph. Ten days later, the police, as part of their ongoing investigation, asked the defendant to participate in a lineup, informing him of his rights, and he agreed.

    Procedural History

    The suppression court determined that the initial stop was based on reasonable suspicion, but the subsequent detention lacked probable cause. The defendant sought to suppress the lineup identification and subsequent statements as fruits of the illegal detention. The lower court denied the motion to suppress. The Appellate Division affirmed.

    Issue(s)

    Whether identifications and statements obtained following an illegal detention must be suppressed as “fruits of the poisonous tree,” even if intervening events and investigation have occurred.

    Holding

    No, because the exploitation of the illegality was sufficiently attenuated by the intervening time and investigation that suppression of the lineup identification and subsequent statements made by the defendant was not required.

    Court’s Reasoning

    The court applied the attenuation doctrine, derived from Wong Sun v. United States, to determine whether the connection between the illegal detention and the subsequent evidence was sufficiently weak to permit the use of the evidence at trial. The court reasoned that the police were entitled to make reasonable inquiry as to the person’s identity when acting on reasonable suspicion, and obtaining name, address, and photograph was simply gathering identification information. The court emphasized that the intervening ten-day period and the independent investigation by the Transit Authority police, coupled with informing the defendant of his rights before the lineup, sufficiently attenuated any taint from the initial unlawful detention. The court noted, “the facts of this case clearly indicate that any taint flowing from the initial unlawful detention was attenuated by the intervening investigation.” The photograph obtained during the detention was used in a photo array, but not offered as evidence at trial. This further supported the conclusion that the lineup identification was independent of the initial detention.

  • People v. Wilson, 21 N.Y.2d 134 (1967): Duty to Secure Defendant’s Return for Trial

    People v. Wilson, 21 N.Y.2d 134 (1967)

    A state has a duty to make a good-faith effort to secure the return of a defendant incarcerated in another jurisdiction for trial; failure to do so violates the defendant’s right to a speedy trial and due process.

    Summary

    Wilson was arrested in 1958 on forgery and petit larceny charges, but was already incarcerated in Alabama. A detainer warrant was filed, but no action was taken to extradite him. Five years later, an indictment was issued. After Wilson was released in Alabama and returned to New York, he moved to dismiss the indictment for lack of prosecution. The Court of Appeals held that the state’s failure to attempt to secure Wilson’s return from Alabama violated his right to a speedy trial, even though he was incarcerated elsewhere. The court emphasized the state’s obligation to actively pursue prosecution once initiated, and the lack of valid justification for the lengthy delay.

    Facts

    In April 1958, Wilson allegedly committed forgery and petit larceny in Nassau County, New York, leading to an arrest warrant.

    In June 1958, Wilson was imprisoned in Alabama for violating his probation on a prior burglary conviction.

    The Nassau County District Attorney filed a detainer warrant with Alabama authorities in July 1958 but made no attempt to extradite Wilson.

    An indictment was handed down in New York in January 1963, charging Wilson with forgery and petit larceny.

    In September 1963, Alabama authorities notified Nassau County of Wilson’s impending release.

    Wilson waived extradition in October 1963 and was returned to New York.

    Procedural History

    In January 1964, Wilson moved to dismiss the indictment under Section 668 of the Code of Criminal Procedure.

    The County Court granted the motion in August 1964.

    The Appellate Division reversed the County Court’s order in July 1966.

    The New York Court of Appeals granted leave to appeal.

    Issue(s)

    Whether the four-and-a-half-year delay in prosecuting Wilson, after the initiation of criminal proceedings but before indictment, violated his due process rights and right to a speedy trial when the delay was due to his incarceration in another state and the prosecution made no effort to secure his return.

    Holding

    Yes, because the State had a duty to make a good-faith effort to secure Wilson’s return for trial and failed to do so without adequate justification, thereby violating his constitutional rights to due process and a speedy trial.

    Court’s Reasoning

    The court reasoned that the delay in bringing Wilson to trial was unreasonable because the Nassau County authorities failed to take any steps to secure his release from Alabama, either before or after the indictment.

    The court rejected the Appellate Division’s conclusion that such action was unnecessary, finding no support in the record for the assertion that the administrative process would have been time-consuming or that Alabama would have been uncooperative.

    The court emphasized that a post-indictment delay is not justified solely because the defendant is imprisoned elsewhere, citing precedents involving both federal and state prisoners. The court noted that procedures exist for securing the release of prisoners in other jurisdictions for trial on pending charges.

    The court dismissed the argument that Alabama’s lack of participation in the Uniform Agreement on Detainers excused the state’s inaction, pointing out that Alabama law (Ala. Code, tit. 15, § 66) allows the Governor to transfer defendants to other states.

    “There is no proper criminological purpose served in holding several prosecutions over a defendant’s head. Neither correction nor deterrence is thus served, especially when the prosecutions withheld are for crimes of much lesser degree than those for which the defendant has been serving time.”

    The court concluded that the People failed to establish good cause for the delay, thereby violating Wilson’s right to a speedy trial and due process.

    The court noted that the delay was particularly unreasonable considering the relatively minor nature of the crimes and the staleness of the nine-year-old charges.

    The decision emphasizes the state’s affirmative obligation to advance prosecution once initiated and rejects the notion that imprisonment in another jurisdiction automatically justifies delay.

  • People v. Wilson, 11 N.Y.2d 421 (1962): Effect of Dismissal for Failure to Indict on Subsequent Indictment

    People v. Wilson, 11 N.Y.2d 421 (1962)

    A dismissal under Section 667 of the New York Criminal Procedure Law, for failure to indict a defendant at the next term of court, does not bar a subsequent indictment for the same offense.

    Summary

    The defendant was initially charged with theft in Magistrate’s Court and released on bail pending grand jury action. After a significant delay, the defendant moved to dismiss the complaint under Section 667 of the New York Criminal Procedure Law because he hadn’t been indicted. Before the motion was heard, the defendant was indicted on charges including the original theft charge. His motion to dismiss was denied, he pleaded guilty, and then appealed, arguing the indictment should have been dismissed under Section 667. The New York Court of Appeals reversed the Appellate Division’s decision, holding that a dismissal under Section 667 does not prevent a subsequent indictment for the same felony offense.

    Facts

    1. May 1959: Defendant arraigned in Magistrate’s Court on theft charge; examination waived; bail granted pending grand jury action.
    2. April 1961: Defendant moved to dismiss the complaint under Section 667 of the Code of Criminal Procedure for failure to indict.
    3. May 1961: Before the dismissal motion was heard, the defendant was indicted on multiple counts, including the original theft charge.
    4. Defendant’s motion to dismiss the complaint was denied.
    5. Defendant arraigned on the indictment, renewed motion to dismiss, which was denied.
    6. Defendant pleaded guilty to one charge and appealed.

    Procedural History

    The County Court of Queens County convicted the defendant. The Appellate Division reversed the conviction, setting aside the guilty plea and granting the defendant’s motion to dismiss the indictment. The People appealed to the New York Court of Appeals.

    Issue(s)

    Whether a dismissal under Section 667 of the Code of Criminal Procedure for failure to indict a defendant at the next term of court bars a subsequent indictment for the same offense, particularly when the indictment is handed up before the dismissal motion is heard.

    Holding

    No, because the statutory language of Section 667 does not mandate such a construction, and the fact of indictment before the dismissal motion is heard constitutes “good cause” for refusing to dismiss the charge.

    Court’s Reasoning

    The Court of Appeals reasoned that Section 667 allows the court to dismiss the “prosecution,” but this does not prevent a subsequent prosecution for the same crime. The court relied on People v. Dillon, 197 N.Y. 254, 256-257, interpreting similar language to mean that “that particular prosecution is terminated” without barring subsequent prosecution. The court stated that such a dismissal has no greater effect than a discharge by a magistrate on preliminary hearing, which does not affect the grand jury’s power to indict later. The fact that an indictment had been handed up before the dismissal motion was heard constituted “good cause” for refusing to dismiss the charge, citing People v. Pearsall, 6 Misc.2d 40. The court also compared Section 667 to Section 668 (dismissal for failure to try at the next term), where dismissal does not prevent reindictment, citing People v. Wilson, 8 N.Y.2d 391, 396. The court highlighted Section 673, which states that a dismissal under Chapter VII “is not a bar” to another prosecution for the same offense if the offense charged is a felony. The court concluded that a dismissal for failure to indict should not have more drastic consequences than a failure to bring to trial after indictment.

  • People v. Wilson, 13 N.Y.2d 277 (1963): No New York Forum for Challenging Out-of-State Convictions

    People v. Wilson, 13 N.Y.2d 277 (1963)

    New York courts will not provide a forum (through coram nobis or habeas corpus) to challenge the validity of a prior out-of-state conviction used to enhance sentencing in New York, unless the rendering court lacked jurisdiction.

    Summary

    Wilson, convicted in New York as a second felony offender based on a prior Florida conviction, sought coram nobis relief in New York, arguing his Florida conviction was unconstitutional because he lacked counsel. The New York Court of Appeals affirmed the denial of relief, reiterating that New York courts will not entertain collateral attacks on out-of-state convictions used for sentencing enhancement unless the rendering court lacked jurisdiction. The court reasoned that while the defendant may have a federal remedy, New York is not obligated to provide a forum to challenge the foreign judgment’s validity.

    Facts

    In 1948, Alfred Wilson was convicted of attempted murder in New York and sentenced as a second felony offender. The predicate felony was a 1931 Florida murder conviction. At sentencing, Wilson admitted the truth of the information regarding his prior felony. In 1962, Wilson filed a coram nobis petition in New York, arguing his Florida conviction was invalid because he was not represented by counsel or advised of his right to counsel in Florida. He submitted affidavits from Florida court officials and an attorney supporting his claim.

    Procedural History

    Wilson sought a writ of error coram nobis in the New York court where he was sentenced as a second felony offender, challenging the validity of the Florida conviction underlying his enhanced sentence. The lower court denied the petition. The New York Court of Appeals affirmed the lower court’s decision, upholding the denial of coram nobis relief.

    Issue(s)

    Whether New York State must provide a forum (through coram nobis or habeas corpus) for a defendant to challenge the constitutional validity of an out-of-state conviction used as a predicate for enhanced sentencing in New York.

    Holding

    No, because New York State is under no duty to provide a forum for attacking a foreign judgment, and New York can rely on the face value of the Florida conviction for sentencing purposes.

    Court’s Reasoning

    The Court of Appeals relied on its prior holding in People v. McCullough, which established that New York courts will not grant a hearing on the validity of an out-of-state conviction used for multiple offender sentencing unless the rendering court lacked jurisdiction. The court reasoned that coram nobis must be brought in the court that entered the judgment under attack, and habeas corpus is only available when the sentencing court lacked jurisdiction. The court acknowledged the Second Circuit’s decision in United States ex rel. La Near v. La Vallee, which held that a defendant in this situation may seek federal habeas corpus relief without exhausting out-of-state remedies, but stated this did not require New York to revise its own rules regarding collateral attacks on foreign judgments. The court expressed concern about the practical difficulties and burdens that would arise if New York courts were required to examine the validity of criminal judgments from other jurisdictions. The court noted that subsequent offender statutes are constitutional and do not require inquiry into the circumstances of the prior adjudication. As stated in the ruling, “the courts of this State have no alternative but to treat the conviction as an effective predicate for multiple offender punishment under section 1941 or section 1942 of the Penal Law.”