The People v. Alexis Sanchez
Issue before the Court: Whether the Appellate Division applied the wrong weight-of-the-evidence standard when it alternately looked to the “two-step approach” of People v. Bleakley “wherein the court must (1) ‘determine whether, based on all the credible evidence, an acquittal would not have been unreasonable[;]’ and (2) ‘weigh the relative probative force of conflicting testimony and the relative strength of conflicting inferences that may be drawn from the testimony’” but also cited cases requiring a finding that the jury’s verdict be “manifestly erroneous or plainly unjustified” before it will overturn a conviction.
Held: While the Court, in a memorandum decision, affirmed the conviction upon finding that the Appellate Division had muddled its way to the correct standard, it nonetheless took the opportunity to advise the intermediate court that aspects of the legal standard that it had appeared to incorporate into its decision should not be followed.
CAL Observes: The Court correctly reminded the Appellate Division that it has de novo review power when assessing weight of the evidence, which means that it can substitute its own credibility determinations. There need be no finding of “manifest erro[r]” for it to do so.
Judge Wilson, in dissent, describes this principle nicely: “An appellate court’s obligation to ‘weigh the probative force of conflicting testimony and the relative strength of conflicting inferences’ is mandatory and nondelegable; it cannot be abdicated to the jury below, even in the exercise of the appellate court’s own discretion.” But, unlike the majority, Judge Wilson would remit the case to the fact-finding court for application of the clarified standard. This is undoubtedly correct. Just as the Appellate Division will not hesitate to remand cases for resentencing where it appears that the trial court misapprehended a defendant’s sentencing range, even if it arrived at a lawful result, remittal to the Appellate Division would ensure that, in Judge Wilson’s memorable words, the court of law is not left to “disassemble” the “soup” of the intermediate court’s decision “to find the meat.”