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& (fee removed from probation conditions)CriminalCourt of Appeals

People v. Adams

Court
Appellate Division of the Supreme Court of the State of New York
Decided
Oct 6, 2026
Docket
Ind No. 781/21|781/21|Appeal No. 7139|Case No. 2022-02012|
Judges
Not listed
Cited as2026 NY Slip Op 05745
Detailed analysis & 3-line summary

AI breakdown

Analyzed Oct 7, 2026

Where this case stands

  1. Supreme Court: sentenced the defendant to five years of probation, including a $375 fee.

  2. This decision ·

    & (fee removed from probation conditions)

TL;DR

  1. 1A man pleaded guilty to having a controlled substance and was sentenced to five years of probation.
  2. 2The court decided to remove a $375 fee from his probation conditions because it wasn't helpful for his rehabilitation.
  3. 3This change was made despite the fee not being legally preserved on , reviewed in the interest of justice.

Key issues

  1. 1

    Can a judge require probation fees for rehabilitation?

    Holding · The court dropped the fee, stating it didn't aid in rehabilitation.

Why it matters

This affects people on probation who may be struggling to pay fines that don’t support their rehabilitation.

The AI breakdown is a reading aid, not legal advice. Always check the opinion for the exact wording.

If you were the judge?

Man sentenced to probation wants fees dropped. Can the court help?

  1. 1A man in the Bronx pleaded guilty to having a controlled substance and got a five-year probation sentence.
  2. 2His probation included a requirement to pay a $375 fee, which he argues isn't fair or helpful for his rehabilitation.
  3. 3The court is deciding if that fee should stay as part of his probation conditions.

Should the court remove the $375 fee from his probation requirements?

Parties

  • Prosecution

    People

  • Appellee

    Adams

Roles are inferred from the case caption.

Opinion of the court
People v Adams 2026 NY Slip Op 05745 October 6, 2026 Appellate Division, First Department Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431. This decision is uncorrected and subject to revision before publication in the Official Reports. The People of the State of New York, Respondent, v Tyrone Adams, Defendant-Appellant. Decided and Entered: October 06, 2026 Ind No. 781/21|781/21|Appeal No. 7139|Case No. 2022-02012| Before: Mendez, J.P., Rodriguez, Pitt-Burke, Rosado, O'Neill Levy, JJ. Caprice R. Jenerson, Office of the Appellate Defender, New York (Ronald Zapata of counsel), for appellant. Darcel D. Clark, District Attorney, Bronx (Mary McGarvey-Depuy of counsel), for respondent. [*1] Judgment, Supreme Court, Bronx County (Raymond L. Bruce, J.), rendered April 27, 2022, convicting defendant, upon his plea of guilty, of criminal possession of a controlled substance in the fifth degree, and sentencing him to a term of probation of five years, unanimously modified, as a matter of discretion in the interest of justice, to the extent of striking the condition of probation requiring him to pay $375 in surcharge and fess as a condition of his probation, and otherwise affirmed, without costs. The condition of probation requiring defendant to pay the surcharge and fees imposed at sentencing will not assist in ensuring that he leads a law-abiding life and is not reasonably related to his rehabilitation (see People v Percy, 234 AD3d 619, 620 [1st Dept 2025]). Although this issue is unpreserved (see People v Brazeal, — NY3d —, 2026 NY Slip Op 03910, *5 [2026]), we review it in the interest of justice. Accordingly, that condition is stricken and the People do not oppose this relief. Despite the invalid waiver of the right to appeal, we perceive no basis for reducing the sentence. THIS CONSTITUTES THE DECISION AND ORDER OF THE SUPREME COURT, APPELLATE DIVISION, FIRST DEPARTMENT. ENTERED: October 6, 2026
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