New York Court of Appeals
The People of the State of New York, Respondent v. William Middlebrooks, Appellant; the People of the State of New…
June 11, 201525 N.Y.3d 516
Summary
The New York Court of Appeals held that a sentencing court must make a record determination of youthful offender eligibility for any defendant convicted of an armed felony (or enumerated sex offense) by evaluating the CPL 720.10(3) factors, even when the defendant does not request such treatment or waives it. The Court reversed the Appellate Division orders and remanded the cases for further proceedings. Justice Stein dissented, arguing that the burden should remain on the defendant to request and prove eligibility.