A New York Supreme Court judge has granted Tajae Sandlers' request to delay his parole revocation hearing until a related criminal suppression hearing is resolved. This ruling affects Sandlers, who was arrested for various charges while on parole, and it underscores the complexities of legal proceedings involving parole and criminal charges.
Judge Noel Mendez issued the ruling on April 6, 2026, in Rensselaer County, stating that proceeding with the parole hearing before the criminal court addresses the legality of the stop and search would violate Sandlers' due process rights. The decision emphasizes the importance of resolving potential legal issues before moving forward with parole revocation.
Background
Tajae Sandlers is the petitioner in this case, having been convicted of Third Degree Robbery in 2020. He was sentenced to an indeterminate term of two to six years and was released on parole in September 2025. However, on October 23, 2025, he was arrested by the Troy Police Department on multiple charges, including Criminal Possession of a Weapon and Criminal Possession of a Controlled Substance, stemming from a stop for jaywalking.
Following his arrest, Sandlers’ parole officer filed a Notice of Violation, alleging he had violated several conditions of his parole. The Board of Parole found sufficient evidence to proceed with a final hearing, which was initially scheduled for November 5, 2025, but was adjourned multiple times. The legal dispute arose when Sandlers sought to delay the final hearing until a suppression hearing could be held regarding the evidence obtained from his arrest.
The Ruling
The court ruled in favor of Sandlers, stating that the final parole revocation hearing should be stayed until the criminal court resolves the suppression issues related to his arrest. Judge Mendez emphasized that proceeding with the parole hearing would violate Sandlers' due process rights, as the legality of the evidence obtained during the stop and search had not yet been determined.
The court ruled, "the better course, where the person seeking to suppress evidence has informed the Board of Parole of their desire to have certain evidence suppressed but must wait for the appropriate procedural posture in the criminal proceeding... is for the parole revocation hearing to be adjourned pending resolution of the motion to suppress."
This ruling reflects the court's recognition of the intricate relationship between criminal proceedings and parole revocation hearings, particularly in cases where the legality of evidence is in question. The decision also references the precedent set in the 1979 case People ex rel. Piccarillo v. New York State Bd. of Parole, which established that the exclusionary rule applies to parole revocation hearings.
Impact
The ruling has significant implications for Sandlers and potentially for other parolees in similar situations. By granting the stay, the court has reinforced the principle that due process must be upheld in parole proceedings, particularly when the evidence against a parolee is contested. This decision may encourage other parolees to assert their rights to challenge the legality of evidence before facing revocation hearings.
Additionally, the ruling may influence how parole boards handle cases involving pending criminal charges. It underscores the necessity for parole authorities to consider the outcomes of related criminal proceedings before making determinations that could lead to revocation of parole.
What's Next
The ruling allows for an appeal, but it is unclear if the respondents will pursue one. There is also a related case, Kadenhead v. Martuscello, currently pending in the Appellate Division, which could further address the issues raised in Sandlers' case. As the legal landscape evolves, the outcomes of these cases may shape future parole procedures in New York.