PEOPLE v. SPOTFORD


196 A.D.2d 179 (1994)

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

Appellate Division of the Supreme Court of the State of New York, Fourth Department.

March 11, 1994


Attorney(s) appearing for the Case

Edward J. Nowak, Rochester (Stephen Bird of counsel), for appellant.

Howard R. Relin, District Attorney of Monroe County, Rochester (Wendy Lehmann of counsel), for respondent.

PINE, CALLAHAN, DOERR and BOEHM, JJ., concur.


GREEN, J. P.

In People v Dokes (79 N.Y.2d 656), the Court of Appeals held that the Sandoval hearing is a material stage of the trial at which the defendant's presence is required, unless the circumstances render such presence superfluous. Violation of the defendant's right to be present ordinarily requires reversal even in the absence of a timely objection (...

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