descrybe logo
You are viewing a free summary from Descrybe.ai. For citation checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.

People v. Hatfield

Citations: 256 A.D.2d 1105; 684 N.Y.S.2d 801; 1998 N.Y. App. Div. LEXIS 14197

Court: Appellate Division of the Supreme Court of the State of New York; December 30, 1998; New York; State Appellate Court

Narrative Opinion Summary

Judgment unanimously affirmed. The defendant was convicted by a jury of third-degree rape (Penal Law § 130.25 [2]), third-degree sexual abuse (Penal Law § 130.55), and three counts of endangering the welfare of a child (Penal Law § 260.10 [1]) for engaging in sexual intercourse with a 16-year-old female. The court found no merit in the defendant's claim that the evidence was insufficient to support the rape conviction. The complainant's testimony indicated that the defendant had intercourse with her, which, if believed by the jury, legally established the element of penetration under the law (People v Chilson cited). Additionally, the defendant waived any constitutional challenge to a prior felony conviction by not raising it during the second felony offender hearing and failing to demonstrate good cause for this omission (CPL § 400.21 [7] cited). The appeal was adjudicated by the Niagara County Court with Judge Fricano presiding.

Legal Issues Addressed

Sufficiency of Evidence in Rape Conviction

Application: The court found no merit in the defendant's claim that the evidence was insufficient to support the rape conviction.

Reasoning: The court found no merit in the defendant's claim that the evidence was insufficient to support the rape conviction.

Third-Degree Rape Conviction under Penal Law § 130.25 [2]

Application: The defendant's conviction for third-degree rape was based on the complainant's testimony, which legally established the element of penetration.

Reasoning: The complainant's testimony indicated that the defendant had intercourse with her, which, if believed by the jury, legally established the element of penetration under the law.

Waiver of Constitutional Challenges to Prior Convictions

Application: The defendant waived any constitutional challenge to a prior felony conviction by failing to raise it during the second felony offender hearing and not demonstrating good cause for this omission.

Reasoning: The defendant waived any constitutional challenge to a prior felony conviction by not raising it during the second felony offender hearing and failing to demonstrate good cause for this omission.