People v. Coger (Michael)
The Appellate Term, Second Department, affirmed the conviction of Michael Coger for attempted criminal obstruction of breathing or blood circulation and harassment in the second degree. Coger had appealed a judgment from the Criminal Court of the City of New York, Queens County, following a nonjury trial. The core of the appeal involved the trial court's denial of a missing witness charge concerning a non-testifying police partner, which Coger argued was crucial given the sole testifying officer's alleged inconsistent testimony and the defense's contradictory witnesses. The Appellate Term found that Coger's arguments regarding the missing witness charge were largely unpreserved for appellate review. Furthermore, the court determined that even if preserved, the absent officer's testimony would have been cumulative, and any error in not drawing a negative inference was harmless in the context of a nonjury trial.