New York felony conviction on 34 counts of falsifying business records

On May 30, 2024, after roughly two days of deliberation, a New York County jury returned a unanimous verdict of guilty on all 34 counts of falsifying business records in the first degree in *People of the State of New York v. Donald J. Trump*, indictment number 71543-2023. The case, tried over six weeks before Justice Juan M. Merchan, centered on payments routed through Michael Cohen to Stephanie Clifford in October 2016 and on the way those payments were recorded in Trump Organization books in 2017 as legal expenses. New York prosecutors charged the records offenses as felonies on the theory that the falsifications were committed with intent to commit or conceal another crime, principally a violation of New York election law.

Trump became the first former president of the United States to be convicted of a felony, and the first sitting or former president to be convicted of any crime. Sentencing was repeatedly delayed by motions tied to the Supreme Court's July 1, 2024 decision in *Trump v. United States*, the federal presidential immunity case, and by the November 2024 election. On January 10, 2025, ten days before Trump returned to the presidency, Justice Merchan imposed an unconditional discharge: a sentence that leaves the conviction on the record but imposes no incarceration, no probation, and no fine. Merchan explained that he was constrained by the unique posture of a president-elect and by Department of Justice positions on the prosecution of sitting presidents.

Trump filed his notice of appeal in October 2025 and the case is pending before the New York Appellate Division, First Department, with merits briefing underway as of the cutoff date. The conviction stands as a matter of New York criminal record. The federal classified documents case in the Southern District of Florida had earlier been dismissed by Judge Aileen Cannon on July 15, 2024, the federal January 6 case was dismissed without prejudice by Special Counsel Jack Smith on November 25, 2024, and the Georgia RICO case was dismissed on November 26, 2025 by Judge Scott McAfee. The New York 34-count conviction therefore remains the only Trump criminal conviction on the record.