The People v. Marc Mitchell
Marc Mitchell, the defendant, appealed his conviction for fraudulent accosting, arguing that the term 'accost' requires a physical, aggressive approach to a specific individual. The New York Court of Appeals rejected this narrow interpretation, stating that dictionaries from the statute's enactment defined 'accost' as 'to approach,' 'speak to first,' or 'address.' The Court found the complaint sufficient, as Mitchell blocked a Manhattan sidewalk with milk crates, requiring pedestrians to walk around him, and asked passing pedestrians to 'Help the homeless,' while allegedly misrepresenting where donations would go. The Court concluded that his actions, including blocking the sidewalk and calling out, constituted accosting. The dissenting opinion argued that the majority's interpretation was too broad, potentially criminalizing protected speech, and that 'accost' implies a more assertive, targeted contact, which was not present in Mitchell's actions. The Appellate Term's order was affirmed.