People v. Thomas
Appellate Division of the Supreme Court of the State of New York
1Opinion of the Court
Judgment unanimously affirmed. Memorandum: We reject the contention that defendant’s absence during a Sandoval conference warrants reversal. Subsequent proceedings held on the record in defendant’s presence constituted a de novo Sandoval hearing (see, People v Russell, 191 AD2d 1001, lv denied 81 NY2d 1019; People v Berger, 188 AD2d 1073, 1074, lv denied 81 NY2d 881).
The contention that defendant was denied effective assistance of counsel is without merit. The constitutional standard for meaningful representation was satisfied (see, People v Baldi, 54 NY2d 137, 147). Upon our review of the…
2Cases cited4 opinions
- People v. BleakleyNew York Court of Appeals · 1987
- People v. BaldiNew York Court of Appeals · 1981
- People v. BergerAppellate Division of the Supreme Court of the State of New York · 1992
- People v. RussellAppellate Division of the Supreme Court of the State of New York · 1993
3Cited by2 opinions
- People v. LynchAppellate Division of the Supreme Court of the State of New York · 1995
- People v. FlaxAppellate Division of the Supreme Court of the State of New York · 1995