Eye on Eagle

People v. Dakota Baldwin


Factual Background: Mr. Baldwin—who had documented mental health and substance abuse
issues—was charged with second-degree assault when, while incarcerated and on suicide watch,
he assaulted a corrections officer who came into his cell to remove his bedsheet. He accepted a
reduced plea to attempted second-degree assault with a maximum sentence of 2 to 4 years. The
Third Department held on appeal, among other things, that there were “no extraordinary
circumstances or abuse of discretion warranting a reduction of the sentence imposed in the
interest of justice.”

Issue Before the Court: Whether the Third Department’s standard, requiring a reviewing court to
find “extraordinary circumstances” or “abuse of discretion” in order to reduce a sentence as
excessive, was an erroneous legal standard in light of CPL 470.15 [6][b], which authorizes the
Appellate Division to reduce “unduly harsh or severe” sentences in the interest of justice.

Holding: The Court unanimously agreed that Mr. Baldwin’s appeal should be dismissed as moot
because he had fully served his sentence by the time of the decision. Justice Wilson concurred to
explain why Mr. Baldwin’s case did not meet the mootness exception: because the Third
Department stopped using its erroneous “extraordinary circumstances” standard once Mr.
Baldwin filed his introductory brief with the Court of Appeals. Therefore, Judge Wilson
observed, Mr. Baldwin had essentially “won.”

Judge Wilson also clarified that, although the question of whether a sentence is excessive is made
in the interest of justice (and therefore typically not reviewable by the Court), when the
interest-of-justice decision reveals the (mis)application of a legal standard – as here – the Court
of Appeals has authority to review that standard.