People v. Sabater — Judges may calculate incarceration tolling after Erlinger
The First Department held that Erlinger does not require juries to calculate incarceration periods used in New York persistent-violent-felony sentencing.
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Constitutional
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People v. G.O. — First Department upholds daily contempt damages for delayed psychiatric transfer
The First Department affirmed a $100-per-day contempt award after OMH left an incompetent defendant at Rikers for months beyond a court-ordered transfer deadline.