People v. Adam Crowder


AD3 order dated October 31, 2013, affirming judgment of conviction.  Decision below: 110 AD3d 1384, 973 NYS2d 871.  Graffeo, J., granted leave March 10, 2014.


ISSUES PRESENTED: (1) Does People v. Louree, 8 NY3d 541, holding that preservation is not required for Catu error, apply where defendant was advised of PRS – not at the time of the plea – but at an earlier court appearance, and PRS was mentioned prior to actual imposition of sentence. (2) The enhancement of defendant’s sentence without a full-blown hearing.