748 F.3d 476
2d Cir.2014Background
- Crandall was convicted of felon-in-possession of firearm and ammunition in the Northern District of New York.
- Crandall argued his trial violated due to a continuous hearing impairment affecting his Sixth Amendment rights.
- The district court knew of Crandall’s hearing concerns only in isolated instances; no continuous notice of impairment was provided.
- The court repeatedly asked Crandall to rely on hearing aids, with accommodations such as louder voices and closer positioning.
- Crandall timely appealed, challenging the adequacy of accommodations and the trial process, seeking reversal or remand.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Sixth Amendment requires accommodations for hearing impairments. | Crandall | Crandall | Sixth Amendment requires reasonable accommodations for hearing impairments. |
| What level of accommodations is required relative to impairment severity. | Crandall | Crandall | Accommodations must be commensurate with impairment severity. |
| Effect of failure to notify the court of a continuous impairment. | Crandall | Crandall | Without notice, defendant entitled only to accommodations for obvious/clear impairment. |
| Whether the district court adequately accommodated Crandall given what it knew. | Crandall | Crandall | Court provided accommodations (repetition, louder voices, etc.) adequate to the known difficulty. |
Key Cases Cited
- Chambers v. Mississippi, 410 U.S. 284 (U.S. 1973) (due process right to fair opportunity to defend)
- Hawkins v. Costello, 460 F.3d 238 (2d Cir. 2006) (meaningful opportunity to present complete defense)
- Crane v. Kentucky, 476 U.S. 683 (U.S. 1986) (right to a fair trial; confrontation and participation must be meaningful)
- Negron v. New York, 434 F.2d 386 (2d Cir. 1970) (defendant must be present to satisfy Sixth Amendment)
- Valladares v. United States, 871 F.2d 1566 (11th Cir. 1989) (court must tailor interpretation/translation to defendant's needs)
- United States v. Weissman, 195 F.3d 96 (2d Cir. 1999) (credibility of trial court findings on defendant’s demeanor)
- Sanchez v. United States, 483 F.2d 1052 (2d Cir. 1973) (translation/accommodation factors depend on defendant’s ability)
- Diaz Berrios v. Diaz Berrios, 441 F.2d 1125 (2d Cir. 1971) (language translation as a factor in proceedings)
- Sandoval v. United States, 347 F.3d 627 (7th Cir. 2003) (district court has wide discretion in implementing interpreter acts)
- Tarbell v. United States, 728 F.3d 122 (2d Cir. 2013) (plain-error review framework for criminal rulings)