New York Court of Appeals
The People of the State of New York v. . John M. Fitzgerald
June 7, 1898156 N.Y. 253
Summary
The New York Court of Appeals reversed the Monroe County conviction of John M. Fitzgerald for second‑degree arson and remanded for a new trial. It held that the trial court erred in admitting a series of character and motive evidence that was not sufficiently connected to the crime and in giving the jury an improper instruction that the defendant’s silence created a presumption of guilt. The Court emphasized the strict requirements for circumstantial proof and the exclusion of collateral bad‑character evidence.