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People v. Parker

Court of Appeals of the State of New York
Oct 7, 1982
57 N.Y.2d 136 (N.Y. 1982)

Summary

describing the facts the trial court must consider before deeming a defendant to have knowingly and voluntarily waived his right to be present as his criminal trial

Summary of this case from Taveras v. Smith

Opinion

Argued August 31, 1982

Decided October 7, 1982

Appeal from the Appellate Division of the Supreme Court in the Fourth Judicial Department, JAMES H. BOOMER, J.

Edward J. Nowak, Public Defender ( Howard A. Bloch of counsel), for appellant.

Donald O. Chesworth, Jr., District Attorney ( Sheldon W. Boyce, Jr., and Kenneth R. Fisher of counsel), for respondent.


The question on this appeal is whether a finding that a criminal defendant has received actual notice of the date for trial and has nonetheless voluntarily failed to appear is sufficient, as a matter of law, to permit the court to proceed to try the defendant in absentia. The courts below held this finding sufficient to establish an implicit relinquishment of a defendant's right to be present at trial. We disagree and reverse.

In February, 1977 defendant was indicted for two counts of criminal sale of a controlled substance in the third degree (Penal Law, § 220.39, subd 1). On Tuesday, July 5, 1977, the trial court notified defense counsel that defendant's case was scheduled for trial on Friday, July 8, 1977. Defense counsel immediately contacted defendant by telephone to notify her of the trial date. She replied that she was seriously ill, that she might not be able to appear for trial, and that she was too ill to meet with counsel prior to the trial date.

Defendant did not appear for trial on July 8. After being informed of defendant's illness by defense counsel, the court adjourned the matter until Monday, July 11. Defendant failed to appear on that day and defense counsel indicated that he had neither heard from nor been successful in locating defendant during the adjournment.

The trial court then conducted a hearing to determine defendant's whereabouts. The prosecutor called Jeanette Harris, who had known defendant for 10 years and who posted bail for her. Mrs. Harris testified, on direct examination, that she spoke with defendant on June 25, 1977, at which time defendant indicated an intention to leave town. Mrs. Harris also stated that defendant never mentioned that she was ill. On cross-examination, Mrs. Harris stated that about one month before the hearing defendant's sister told defendant to leave town but that defendant responded by saying she would not flee. She testified that her son, James Harris, told her defendant was "out in the street".

After Mrs. Harris testified, defense counsel told the court that defendant never told him she was planning to leave the jurisdiction. The court found that defendant's absence was voluntary and that she had voluntarily waived her right to be present at trial. Pursuant to court order and over defense counsel's objection, defendant was tried in absentia. No effort was made to secure the presence of the defendant through the use of a bench warrant.

At trial Officer Ruffin, of the Drug Enforcement Administration (DEA) Task Force of Monroe County, testified to purchasing cocaine and morphine from defendant. Two other DEA officers, who were observing Ruffin's vehicle from a distance of 60 feet at the time of the sale identified defendant as the individual who entered the vehicle when the transaction occurred. At the close of the People's case defense counsel called no witnesses but indicated that he would have called defendant had she not been tried in absentia, and that she would have rendered an exculpatory explanation of the transaction.

The jury returned a verdict finding defendant guilty on both counts of criminal sale of a controlled substance in the third degree. She was sentenced in absentia to an indeterminate term of two years to life in prison on each count, to run concurrently.

The Appellate Division affirmed the judgment of conviction, without opinion. We conclude that the trial court's factual finding of voluntary absence from court on the day scheduled for her appearance is alone insufficient as a matter of law to establish an implicit waiver of defendant's right to be present at trial so as to permit the court to try defendant in absentia.

A defendant's right to be present at a criminal trial is encompassed within the confrontation clauses of the State and Federal Constitutions (NY Const, art I, § 6; US Const, 6th Amdt) and the Criminal Procedure Law (CPL 260.20, 340.50). Of course the right to be present may, as a general matter, be waived under both Constitutions ( Diaz v United States, 223 U.S. 442; People v Byrnes, 33 N.Y.2d 343).

More specifically, we have recently held that a waiver of the right to be present at a criminal trial may be inferred from certain conduct engaged in by the defendant after the trial has commenced. Thus in People v Epps ( 37 N.Y.2d 343, cert den 423 U.S. 999), we held that defendant waived his right to be present when, after attending his trial for the first two days, he refused to leave his cell and attend further proceedings as part of his participation in an inmate boycott of the courts. We noted that prison personnel had repeatedly warned the defendant of the consequences of his refusal to leave his cell. Similarly, in People v Johnson ( 37 N.Y.2d 778), we held that the defendant's behavior in disrupting trial proceedings and his repeated requests to leave the courtroom, along with the court's explanation of the consequence that the trial would proceed without him, were sufficient to waive the defendant's right to be present at the trial (see, also, Taylor v United States, 414 U.S. 17).

Although the right to be present at a criminal trial may be waived, the right is of a fundamental constitutional nature and therefore the validity of any waiver including one which could be implied, must be tested according to constitutional standards. Thus, in People v Epps (37 N.Y.2d, supra, at p 350) we noted that the key issue was whether this defendant knowingly, voluntarily and intelligently relinquished his known right ( Johnson v Zerbst, 304 U.S. 458, 464).

The People argue that a forfeiture rather than a waiver analysis should be applied in the trial in absentia context when the trial is commenced in defendant's absence. It is true that the forfeiture of a right may occur even though a defendant never made an informed, deliberate decision to relinquish that right. While waiver requires a knowing, voluntary and intelligent decision, which may be either express or implied, forfeiture occurs by operation of law without regard to defendant's state of mind (see, generally, Westen, Away from Waiver: A Rationale for the Forfeiture of Constitutional Rights in Criminal Procedure, 75 Mich L Rev 1214). The People argue that forfeiture of the right to be present at trial occurs as a matter of law whenever defendant knows of the court date and nonetheless voluntarily fails to appear.

We reject this contention and conclude that Epps and Johnson ( supra), require the application of a constitutional waiver analysis to the facts now before us. In Epps and Johnson the defendants were present when trial commenced and were warned of the consequences of their conduct. In each of those cases the defendant's conduct represented a clear expression of a desire not to be present at trial under any circumstances and therefore it would be inaccurate to say that the defendants in those cases renounced their right to be present. In those cases we required a voluntary, knowing and intelligent waiver of the right to be present at trial. In the case before us, considering the defendant's knowledge at the time of her disappearance, there is no less reason for applying a waiver analysis. Certainly the mere fact of her disappearance presents a far more ambiguous situation than was present in Epps or Johnson for it does not appear that she was advised at any time by anyone that if she did not appear in court on the scheduled date the trial would proceed without her.

In order to effect a voluntary, knowing and intelligent waiver, the defendant must, at a minimum, be informed in some manner of the nature of the right to be present at trial and the consequences of failing to appear for trial (see Schneckloth v Bustamonte, 412 U.S. 218, 243-244; Brady v United States, 397 U.S. 742, 748). This, of course, in turn requires that defendant simply be aware that trial will proceed even though he or she fails to appear. As noted above, the defendants in Epps and Johnson were both expressly told that trial would proceed in their absence.

As we have previously noted, the record before us is devoid of any evidence indicating that defendant was ever apprised or otherwise aware that her trial would proceed in her absence. Defendant told her counsel that she might not be able to appear for trial due to illness and the trial court, after a hearing, determined that she had notice of a day certain for her scheduled appearance and deliberately failed to appear. However, the court made no finding regarding whether defendant was aware that the consequence of her absence would be that her trial would proceed without her being present.

Moreover, nothing in the record provides a basis for implying a waiver as a matter of law from the circumstances. In Taylor v United States (414 US, supra, at p 20) the defendant absented himself voluntarily after attending the opening of his trial. The Supreme Court implied a waiver from that conduct as a matter of law, stating: "It seems equally incredible to us, as it did to the Court of Appeals, `that a defendant who flees from a courtroom in the midst of a trial — where judge, jury, witnesses, and lawyers are present and ready to continue — would not know that as a consequence the trial could continue in his absence'" (citation omitted). A similar waiver was implied from mere voluntary failure to appear for trial in the multiple defendant case of United States v Tortora ( 464 F.2d 1202, cert den sub nom. Santoro v United States, 409 U.S. 1063). No similar circumstances are presented in the case at bar.

We consider it appropriate to emphasize that even after the court has determined that a defendant has waived the right to be present at trial by not appearing after being apprised of the right and the consequences of nonappearance, trial in absentia is not thereby automatically authorized. Rather, the trial court must exercise its sound discretion upon consideration of all appropriate factors, including the possibility that defendant could be located within a reasonable period of time, the difficulty of rescheduling trial and the chance that evidence will be lost or witnesses will disappear (see United States v Peterson, 524 F.2d 167). In most cases the simple expedient of adjournment pending execution of a bench warrant could provide an alternative to trial in absentia unless, of course, the prosecution can demonstrate that such a course of action would be totally futile.

Accordingly, the order of the Appellate Division should be reversed and the matter remitted for a new trial.

Chief Judge COOKE and Judges JASEN, JONES, FUCHSBERG and MEYER concur; Judge GABRIELLI taking no part.

Order reversed and a new trial ordered.


Summaries of

People v. Parker

Court of Appeals of the State of New York
Oct 7, 1982
57 N.Y.2d 136 (N.Y. 1982)

describing the facts the trial court must consider before deeming a defendant to have knowingly and voluntarily waived his right to be present as his criminal trial

Summary of this case from Taveras v. Smith

In People v. Parker, 57 N.Y.2d 136 (1982), decided four months after Clark's sentencing, but before his appeal was heard, the Court of Appeals was again presented with the question of a defendant's absence from trial.

Summary of this case from Clark v. Stinson

advising defendant of the right to be present and that the consequences of nonappearance could be trial in absentia

Summary of this case from Kordish v. Martuscello

requiring that defendants must be informed of the right to be present at trial and the consequences of failing to appear

Summary of this case from Bidinost v. Colvin

In Parker, the New York Court of Appeals held that "[i]n order to effect a voluntary, knowing and intelligent waiver, the defendant must, at a minimum be informed in some manner of the nature of the right to be present at trial and the consequences of failing to appear for trial."

Summary of this case from Cedeno v. Conway

In People v. Parker, 57 N.Y.2d 136 (1982), the controlling New York case on this issue, the New York Court of Appeals relied on two Supreme Court cases when it stated that "[i]n order to effect a voluntary, knowing and intelligent waiver, the defendant must, at a minimum be informed in some manner of the nature of the right to be present at trial and the consequences of failing to appear for trial."

Summary of this case from Green v. Ercole

setting forth the procedures that must be followed before a defendant can be tried in absentia

Summary of this case from Taveras v. Smith

In People v. Parker, 57 N.Y.2d 136, 141 (1982), the New York Court of Appeals held that before a defendant could be deemed to have waived the right to be present at trial, the defendant "must, at a minimum, be informed in some manner of the nature of the right to be present at trial and the consequences of failing to appear for trial.

Summary of this case from Spencer v. McCray

In Parker, the Arkansas Supreme Court held that the defendant's burglary was a facilitating step along the way in fulfilling his intent to commit murder.

Summary of this case from People v. Cahill

In Parker (supra), the court held that a defendant who had received notice of the date for trial did not waive her right to be present by voluntarily failing to appear on the assigned date where she had not been warned that the trial would proceed in her absence (People v Parker, supra, pp 138, 141).

Summary of this case from People v. Sanchez

In Parker, we held that to effect a voluntary, knowing and intelligent waiver, "the defendant must, at a minimum, be informed in some manner of the nature of the right to be present at trial and the consequences of failing to appear for trial" (People v Parker, supra, at p 141).

Summary of this case from People v. Trendell

In People v. Parker (57 N.Y.2d 136, 142) the Court of Appeals indicated that: "even after the court has determined that a defendant has waived the right to be present at trial by not appearing after being apprised of the right and the consequences of nonappearance, trial in absentia is not thereby automatically authorized.

Summary of this case from People v. Ramos

In Parker, the Court of Appeals stated that a defendant must be informed in some manner of the nature of the right to be present at trial and the consequences of failing to appear at trial in order to effect a voluntary, knowing and intelligent waiver of his right to be present at trial.

Summary of this case from People v. Coumbes

In Parker, the defendant told her lawyer, three days before trial, that she was seriously ill and would probably not make trial.

Summary of this case from People v. Martinez

In Parker (supra, p. 141), the Court of Appeals stated that, "[i]n order to effect a voluntary, knowing and intelligent waiver, the defendant must, at a minimum, be informed in some manner of the nature of the right to be present at trial and the consequences of failing to appear for trial * * * This, of course, in turn requires that defendant simply be aware that trial will proceed even though he or she fails to appear."

Summary of this case from People v. Scott

In People v Parker (57 N.Y.2d 136), the Court of Appeals recently concluded that a "trial court's factual finding of voluntary absence from court on the day scheduled for [his] appearance is alone insufficient as a matter of law to establish an implicit waiver of defendant's right to be present at trial so as to permit the court to try defendant in absentia" (id. at p 139).

Summary of this case from People v. Thompson

In People v. Parker, 57 N.Y.2d 136, 140, 454 N.Y.S.2d 967, 440 N.E.2d 1313 (1982), in the context of trial in absentia, the Court explicitly rejected the application of forfeiture analysis and held that constitutional waiver analysis was required where defendant had failed to appear for trial and trial had not yet commenced.

Summary of this case from People v. Roe

In People v. Parker, 57 N.Y.2d 136, 140, 454 N.Y.S.2d 967, 440 N.E.2d 1313 (1982), in the context of trial in absentia, the Court explicitly rejected the application of forfeiture analysis and held that constitutional waiver analysis was required where defendant had failed to appear for trial and trial had not yet commenced.

Summary of this case from People v. Roe

In People v. Parker, 57 NY2d 136, 140 (1982), in the context of trial in absentia, the Court explicitly rejected the application of forfeiture analysis and held that constitutional waiver analysis was required where defendant had failed to appear for trial and trial had not yet commenced.

Summary of this case from People v. Roe

In Parker, the People argued that whenever a defendant is informed of a trial date and voluntarily fails to appear, a forfeiture occurs as a matter of law.

Summary of this case from People v. Ocasio

In People v Parker (57 N.Y.2d 136), for example, the Court of Appeals held that a defendant who failed to appear the day her trial was scheduled to occur did not waive her right to be present at the trial, since there was no evidence that the defendant had been informed that the trial would proceed in her absence. Similarly, in this case the defendant was not told that he would receive notice of the time and place of his Grand Jury appearance only by being present in the courtroom on August 17th or thereafter.

Summary of this case from People v. Ocasio

In People v. Parker (57 N.Y.2d 136), the Court of Appeals held that before a trial in absentia there must be a factual finding that defendant was informed of his right to be present and informed that trial would proceed without him.

Summary of this case from People v. Green

In People v Parker (57 N.Y.2d 136), the Court of Appeals held that before a defendant could be tried in absentia, the People were obligated to demonstrate by constitutional standards that he had voluntarily and intelligently relinquished his right to be present.

Summary of this case from Matter of Leroy B

In Parker (supra) the court drew special attention to the fact that no bench warrant had ever been issued for that defendant.

Summary of this case from People v. Molina

In Parker, at page 142, the court wrote: "Rather, the trial court must exercise its sound discretion upon consideration of all appropriate factors, including the possibility that defendant could be located within a reasonable period of time, the difficulty of rescheduling trial and the chance that evidence will be lost or witnesses will disappear (see United States v Peterson, 524 F.2d 167)."

Summary of this case from People v. Cruz
Case details for

People v. Parker

Case Details

Full title:THE PEOPLE OF THE STATE OF NEW YORK, Respondent, v. VICKI PARKER, Appellant

Court:Court of Appeals of the State of New York

Date published: Oct 7, 1982

Citations

57 N.Y.2d 136 (N.Y. 1982)
454 N.Y.S.2d 967
440 N.E.2d 1313

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