People v. Bonaparte

In People v. Bonaparte (78 N.Y.2d 26, 574 N.E.2d 1027, 571 N.Y.S.2d 421 [1991]), a court officer, directed by the trial court, told a deliberating jury that it would be sequestered and should stop deliberating. The court, however, failed to instruct the jurors not to deliberate while sequestered. The Court affirmed the conviction, concluding that the court officer's communication was ministerial and that the court's failure, unprotested, did not present an issue of law for the Court's review.