In a case viewed as a significant development in New York's criminal law, a state appellate court has recognized that a freestanding claim of "actual innocence" is a ground for defendants to challenge their convictions.
Source: http://www.law.com/jsp/law/sign_me_in.jsp?article=http://www.newyorklawjournal.com/PubArticleNY.jsp?id=1202638658667&rss=newswire
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