People v. Becoats
2011 NY Slip Op 7306
NY2011Background
- Defendants Corey Becoats and Jason Wright were convicted of second-degree murder (depraved indifference) and first-degree robbery for the beating and robbery of Hayden Spears; Sherrod Carter was the third participant and not apprehended at trial.
- Two eyewitnesses, Lorraine Small and Nicholas Carter (Sherrod Carter's brother), testified; both have significant criminal records and gave accounts of the attack involving multiple assailants, including a gun Wright removed from Spears’ pants.
- Spears died from blunt-force trauma; forensic evidence supported the attack narrative but provided no independent identity of the attackers beyond the eyewitnesses.
- Appellate Division reduced Wright’s murder conviction to manslaughter in the second degree and affirmed the rest; this Court granted leave to appeal for both defendants.
- The trial involved a duplicitous-robbery count (gun and sneakers) not preserved for appeal; defense sought to adjourn for a federal witness, Michael Bishop, but the adjournment was denied; later, the sole evidence linking defendants to the attack rested on two witnesses with potential credibility concerns.
- The key legal ruling centers on the admissibility of evidence about a planning conversation overheard by Small, which Wright sought to introduce to show his absence from planning; the Court held the conversation was improperly excluded and remanded Wright for a new trial; Becoats’ adjournment denial was left with the majority’s determination.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Duplicitous robbery count preserved error? | Wright and Becoats argue duplicitous indictment. | Defendants claim separate crimes should be charged. | Not preserved; Court declines review. |
| Admission of witness planning conversation (Small deposition)? | People rely on eyewitnesses; no issue. | Wright seeks evidence of planning excluding Wright’s involvement. | Exclusion error; warrants new trial for Wright. |
| Adjournment to secure federal witness Bishop? | Defense needed Bishop’s testimony to bolster theory. | Trial court acted within discretion. | No abuse; adjournment denied; in dissent view, error acknowledged for Becoats. |
| Sufficiency of evidence for robbery of gun vs sneakers? | Evidence shows forcible taking from Spears. | Gun lacked proof of intent to permanently deprive; sneakers sufficient. | Sneakers supported robbery; gun basis not independently sufficient. |
| Grants of new trial remedy for Wright? | Evidence exclusion undermines fairness. | Trial integrity preserved; other issues merit affirmance. | Wright entitled to new trial; Becoats' adjournment ruling affirmed (majority). |
Key Cases Cited
- People v. Patterson, 39 NY2d 288 (NY 1976) (preservation and mode of proceedings error limits)
- People v. Ahmed, 66 NY2d 307 (NY 1985) (fundamental error exceptions; missteps not always reviewable)
- Griffin v. United States, 502 U.S. 46 (U.S. 1991) (general verdict ok when based on factually supported grounds; not when dependent on unsupported theory)
- People v. Martinez, 83 NY2d 26 (NY 1993) (distinguishes legal vs. factual inadequacy in verdicts)
- Hillmon, 145 U.S. 285 (U.S. 1892) (present-intent exception to hearsay; relevance to planning conversations)
- People v. James, 93 NY2d 620 (NY 1999) (hearsay and admissibility scope for exceptions demonstrating intent)
- People v. Foy, 32 NY2d 473 (NY 1973) (adjourment discretionary considerations; fundamental rights impact)