People v. Haynes

Citation: 2019 NY Slip Op 53941Docket: 109788

Court: Appellate Division of the Supreme Court of the State of New York; November 26, 2019; New York; State Appellate Court

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In *People v. Haynes*, the Appellate Division, Third Department upheld Jody C. Haynes' conviction for first-degree burglary and fourth-degree criminal possession of a weapon. The case stemmed from a November 2016 incident where Haynes unlawfully entered the home of a coworker, threatened her with a knife, and was subsequently charged. Following a jury trial, he was sentenced to 20 years in prison for the burglary conviction, with five years of post-release supervision, and a concurrent one-year jail term for the weapon charge.

Haynes contended that the evidence was insufficient to demonstrate his intent to commit a crime upon entering the victim's residence. The court, however, emphasized the standard for reviewing legal sufficiency claims, which involves assessing the evidence favorably for the prosecution. The court noted that a person is guilty of first-degree burglary if they enter unlawfully with the intent to commit a crime and use or threaten to use a dangerous instrument during the entry or while fleeing.

The court referenced established legal principles indicating that intent can be inferred from the circumstances of the entry, the defendant's presence, and their actions or statements. It was highlighted that Haynes and the victim had a pre-existing relationship, during which the victim had repeatedly rejected his romantic advances. Just days before the incident, she had informed him of her relationship status, which could provide context for Haynes' actions leading up to the crime. The evidence presented at trial was deemed sufficient to support the jury's verdict.

Defendant persistently messaged the victim, seeking information about her boyfriend and the presence of her family members at home. On June 7, 2016, after finishing an overnight shift with the victim, he became increasingly agitated due to her lack of response. He sent messages accusing her of being 'fake' and urged her to block him on Facebook. Following this, the victim dropped her son off at school and prepared to meet a friend. When she answered her door after multiple bell rings, the defendant forced his way in, pushed her down, and threatened her with a steak knife. After calming him down, the victim convinced him to leave and reported the incident to the police later that day. During a police interview, the defendant admitted to being angry and intentionally driving to the victim's home with the knife. Despite claiming he did not intend to harm her and only wanted to talk, evidence presented at trial supported a conclusion that he intended to commit a crime upon entering her home. The court ruled there was sufficient evidence for a jury to find him guilty of first-degree burglary. Additionally, the trial included Molineux evidence, which was deemed admissible under recognized exceptions, balancing its probative value against any potential prejudicial effect.

The County Court's admission of statements made by the defendant to a coworker, where he referred to the victim as 'a whore,' was deemed relevant for establishing the defendant's motive and intent regarding the charged crime. These statements provided necessary context for the defendant's state of mind, particularly his anger and obsession with the victim, and were considered more probative than prejudicial. The court found no merit in the defendant's claim that it erred by denying his request for a jury instruction on the lesser included offense of second-degree criminal trespass, as there was no evidence suggesting a noncriminal purpose for his forcible entry into the victim's home while brandishing a steak knife and making threats. The court also rejected the argument that a harsher sentence following trial indicated punishment for exercising the right to trial, noting that a greater sentence was not conclusive evidence of vindictiveness. The defendant's criminal history, especially regarding violence towards women, did not warrant sentence reduction. The court acknowledged the defendant's expressions of remorse in imposing a sentence less than the maximum allowable. The judgment was affirmed, with additional notes indicating that the victim had no desire for further communication with the defendant outside of work and that the defendant's challenge regarding hearsay was unpreserved for review.