People v Black
2011 NY Slip Op 09664 [90 AD3d 1066]
December 27, 2011
Appellate Division, Second Department
As corrected through Wednesday, February 1, 2012


The People of the State of New York, Respondent,
v
CraigBlack, Appellant.

[*1]Lynn W. L. Fahey, New York, N.Y. (Joshua M. Levine of counsel), for appellant.

Charles J. Hynes, District Attorney, Brooklyn, N.Y. (Leonard Joblove, Jodi L. Mandel, andMeg D. Holzer of counsel), for respondent.

Appeal by the defendant from a judgment of the Supreme Court, Kings County (Heffernan,Jr., J.), rendered July 30, 2007, convicting him of criminal sale of a controlled substance in thethird degree and criminal possession of a controlled substance in the seventh degree, upon a juryverdict, and imposing sentence.

Ordered that the judgment is affirmed.

"A criminal defendant has a fundamental constitutional right to present witnesses in his orher own defense" (People v Pitt, 84AD3d 1275, 1276 [2011]; see Chambers v Mississippi, 410 US 284, 302 [1973])."Moreover, '[a] [trial] court's discretion in evidentiary rulings is circumscribed by the rules ofevidence and the defendant's constitutional right to present a defense' " (People v Pitt, 84AD3d at 1276, quoting People v Carroll, 95 NY2d 375, 385 [2000]; see People v Diaz, 85 AD3d 1047,1050 [2011]; People v Ocampo, 28AD3d 684, 685 [2006]). However, a defendant's right to present a defense is not absolute (see People v Hayes, 17 NY3d 46,53 [2011], cert denied 565 US —, 132 S Ct 844 [2011]; People v Williams, 81 NY2d 303, 313 [1993]), and thetrial court has wide latitude to exclude evidence that is repetitive, only marginally relevant, orposes an undue risk of confusion of the issues (see People v Bowen, 67 AD3d 1022, 1023 [2009]; People vCelifie, 287 AD2d 465, 466 [2001]; People v Cancel, 176 AD2d 748, 749 [1991]).

The Supreme Court, under the circumstances here, providently exercised its discretion inexcluding testimony of a witness called by the defendant that there was a video camera outsidethe building where the defendant allegedly completed a drug sale to an undercover police officer(see People v Hayes, 17 NY3d46 [2011]). Dillon, J.P., Florio, Chambers and Miller, JJ., concur.


NYPTI Decisions © 2026 is a project of New York Prosecutors Training Institute (NYPTI) made possible by leveraging the work we've done providing online research and tools to prosecutors.

NYPTI would like to thank New York State Division of Criminal Justice Services, New York State Senate's Open Legislation Project, New York State Unified Court System, New York State Law Reporting Bureau and Free Law Project for their invaluable assistance making this project possible.

Install the free RECAP extensions to help contribute to this archive. See https://free.law/recap/ for more information.