People v. Crimmins
- Decided
- February 25, 1975
- Status
- Published
- Jurisdiction
- New York
Cited 6,387 timesNo negative treatment found in this library
What later courts said
- holding that an error is prejudicial “if an appellate court concludes that there is a significant probability, rather than only a rational possibility, in the particular case that the jury would have acquitted the defendant had it not been for the error or errors which occurred” — Strzelecki v. Cunningham (2019)
- finding that errors are considered harmless only when “there is no reasonable possibility that the error might have contributed to defendant’s conviction and that it was thus harmless beyond a reasonable doubt” — Diaz v. Bell (2022)
- setting forth test for harmless constitutional error as no reasonable possibility that the error might have contributed to defendant's conviction — McGhee v. Uhler (2019)
Each line is a later court’s own words about this case, not a summary. Read the opinion before relying on it.
How the opinion begins
Jones, J.
On this appeal we are called on principally to consider the doctrine of harmless error as applied to errors which occurred on defendant’s second trial. In this case a mother was charged with criminal responsibility in connection with the deaths of her son and her daughter. On her first trial defendant was charged only with the death of the daughter and was convicted of manslaughter. On appeal this conviction was reversed and a new trial was ordered. (People v. Crimmins, 33 A D 2d 793, affd. 26 N Y 2d 319.) On her second trial the jury convicted defendant of murder of her son and manslaughter of her daughter. The Appellate Division then reversed the conviction of murder of the son and dismissed the charge against defendant with respect to his death. (People v. Crimmins, 41 A D 2d 933.) As to the manslaughter conviction, the Appellate Division also reversed defendant’s conviction but ordered a new trial with respect to her responsibility for the death of her daughter. The case is now before us on appeal by the People.
The procedural aspects of this appeal and of our dispositions of its several branches call for exposition. The ultimate issues turn on the procedural significance and consequences properly to be attached to errors of law which occurred during the second trial. We conclude that these errors fall into separate categories calling for different legal results.
Cite this
People v. Crimmins, 36 N.Y.2d 230 (1975)Read the full opinion
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