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PEOPLE v. BOYD
Appellate Division of the Supreme Court of New York, Fourth Department.
Apr 14, 1989
Judgment unanimously affirmed. Memorandum: Although the court's Sandoval ruling (see, People v. Sandoval, 34 N.Y.2d 371) permitting cross-examination of defendant concerning two pending criminal charges may have been error (see, People v. Betts, 70 N.Y.2d 289), the error was rendered harmless by the overwhelming evidence of defendant's guilt based upon the in-court identifications of defendant at trial by the two victims of the robbery (see, People v. Crimmins, 36 N.Y.2d 230).
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