United States v. Crandall, No. 12-3313 (2d Cir. 2014)Annotate this Case
Defendant appealed his conviction for being a felon in possession of a firearm and ammunition, arguing that his due process rights were violated because a hearing impairment allegedly prevented him from exercising his Sixth Amendment rights to, inter alia, be present, assist in his defense, and confront witnesses against him. The court held that the Sixth Amendment requires reasonable accommodations for hearing-impaired criminal defendants during judicial proceedings and that such accommodations must be commensurate with the severity of the hearing impairment. Where a criminal defendant does not notify the district court of the impairment, however, he was only entitled to accommodations commensurate with the degree of difficulty that was, or reasonably should have been, clear or obvious to the district court. In this case, the court held that defendant received accommodations commensurate with the degree of difficulty that was, or reasonably should have been, clear or obvious to the district court. Accordingly, the court affirmed the judgment of the district court.