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DEFENDANT WAS ENTITLED TO A HEARING ON HIS MOTION TO SET ASIDE HIS CONVICTION ON INEFFECTIVE ASSISTANCE GROUNDS, WHETHER THE OUTCOME OF THE TRIAL WOULD HAVE BEEN DIFFERENT ABSENT DEFENSE COUNSEL’S MISTAKES IS NOT THE FOCUS OF THE INEFFECTIVE-ASSISTANCE ANALYSIS.

The First Department, over an extensive two-justice dissent, determined defendant was entitled to a hearing on his motion to set aside the judgment of conviction based upon ineffective assistance of counsel. Defendant alleged that he wanted to testify but didn’t because the Sandoval hearing was never completed and defense counsel never asked that it be completed. Defendant further alleged defense counsel told defendant not to testify and threatened to leave the case if defendant insisted. Defendant also alleged defense counsel was paid to hire an expert on DNA evidence but never did. Defendant submitted expert opinion evidence that cross-examination of the People’s DNA expert could have been more effective had the defense been advised by a defense expert.  The First Department explained that an inquiry into whether a defendant received effective assistance is not an inquiry into whether the outcome of the trial would have been different absent the mistakes by counsel. The only issue is whether defendant received a fair trial:

It is well established that a defendant who is represented by counsel nevertheless retains authority over certain fundamental decisions regarding the case, including the decision whether to testify in his or her behalf … . The decision to testify in one’s behalf is personal and can be waived only by the defendant, not counsel alone … . Defendant’s affidavit submitted with the 440.10 motion made clear that he informed trial counsel that he wished to testify, depending on the outcome of the Sandoval hearing. In light of this affidavit, a hearing is required to more fully explore the circumstances surrounding trial counsel’s alleged representation to the court that defendant would not be testifying, and whether defendant was aware of, and concurred with, that decision. * * *

The dissent argues that no hearing is necessary because “the alleged deficiencies in trial counsel’s performance . . . could not have affected the result of the trial.” That, however, is not the standard for reviewing claims of ineffective assistance of counsel under the State Constitution. New York “refuse[s] to apply the harmless error doctrine in cases involving substantiated claims of ineffective assistance” … . Although whether a defendant would have been acquitted but for counsel’s errors is relevant, a state claim of ineffective assistance “is ultimately concerned with the fairness of the process as a whole rather than its particular impact on the outcome of the case” … . “Thus, under our State Constitution, even in the absence of a reasonable probability of a different outcome, inadequacy of counsel will still warrant reversal whenever a defendant is deprived of a fair trial” … . People v Mercado, 2017 NY Slip Op 01439, 1st Dept 2-23-17

 

CRIMINAL LAW (DEFENDANT WAS ENTITLED TO A HEARING ON HIS MOTION TO SET ASIDE HIS CONVICTION ON INEFFECTIVE ASSISTANCE GROUNDS, WHETHER THE OUTCOME OF THE TRIAL WOULD HAVE BEEN DIFFERENT ABSENT DEFENSE COUNSEL’S MISTAKES IS NOT THE FOCUS OF THE INEFFECTIVE-ASSISTANCE ANALYSIS)/ATTORNEYS (CRIMINAL LAW, (DEFENDANT WAS ENTITLED TO A HEARING ON HIS MOTION TO SET ASIDE HIS CONVICTION ON INEFFECTIVE ASSISTANCE GROUNDS, WHETHER THE OUTCOME OF THE TRIAL WOULD HAVE BEEN DIFFERENT ABSENT DEFENSE COUNSEL’S MISTAKES IS NOT THE FOCUS OF THE INEFFECTIVE-ASSISTANCE ANALYSIS)/INEFFECTIVE ASSISTANCE (DEFENDANT WAS ENTITLED TO A HEARING ON HIS MOTION TO SET ASIDE HIS CONVICTION ON INEFFECTIVE ASSISTANCE GROUNDS, WHETHER THE OUTCOME OF THE TRIAL WOULD HAVE BEEN DIFFERENT ABSENT DEFENSE COUNSEL’S MISTAKES IS NOT THE FOCUS OF THE INEFFECTIVE-ASSISTANCE ANALYSIS)/SET ASIDE CONVICTION, MOTION TO (DEFENDANT WAS ENTITLED TO A HEARING ON HIS MOTION TO SET ASIDE HIS CONVICTION ON INEFFECTIVE ASSISTANCE GROUNDS, WHETHER THE OUTCOME OF THE TRIAL WOULD HAVE BEEN DIFFERENT ABSENT DEFENSE COUNSEL’S MISTAKES IS NOT THE FOCUS OF THE INEFFECTIVE-ASSISTANCE ANALYSIS)

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NO INTERLOCUTORY APPEAL FROM DENIAL OF A CIVIL MOTION MADE IN THE CONTEXT OF A CRIMINAL PROCEEDING.

The First Department determined the denial of a civil motion seeking discovery (letters rogatory) oversees which was made in the context of a criminal proceeding could not be the subject of an interlocutory appeal:

In this matter where an indictment has been filed, a criminal trial is pending, and defendants seek information via letters rogatory for use at their criminal trial, the denial of the application for such letters is part of the criminal proceeding, notwithstanding that the application was brought under CPLR 3108 … .

“It is well established that no appeal lies from a determination made in a criminal proceeding unless specifically provided for by statute”  … . The order appealed from is not a disposition listed in CPL 450.10 or 450.15, and is therefore not an appealable paper … . A “defendant may only appeal after conviction” … , and may not obtain an interlocutory appeal by claiming to invoke the court’s civil jurisdiction. People v DePalo, 2017 NY Slip Op 01441, 1st Dept 2-23-17

 

CRIMINAL LAW (NO INTERLOCUTORY APPEAL FROM DENIAL OF A CIVIL MOTION MADE IN THE CONTEXT OF A CRIMINAL PROCEEDING)/APPEALS (CRIMINAL LAW, NO INTERLOCUTORY APPEAL FROM DENIAL OF A CIVIL MOTION MADE IN THE CONTEXT OF A CRIMINAL PROCEEDING)/CIVIL PROCEDURE (CRIMINAL LAW, NO INTERLOCUTORY APPEAL FROM DENIAL OF A CIVIL MOTION MADE IN THE CONTEXT OF A CRIMINAL PROCEEDING)/LETTERS ROGATORY (CRIMINAL LAW, APPEALS, NO INTERLOCUTORY APPEAL FROM DENIAL OF A CIVIL MOTION MADE IN THE CONTEXT OF A CRIMINAL PROCEEDING)

ALTHOUGH DEFECTS IN GUILTY PLEA NOT PRESERVED BY A MOTION, PLEA VACATED IN THE INTEREST OF JUSTICE BECAUSE JUDGE DID NOT ENSURE DEFENDANT UNDERSTOOD THE CONSTITUTIONAL RIGHTS HE WAS GIVING UP.

The Third Department determined defendant’s waiver of appeal was inadequate and there was no assurance defendant understood the constitutional rights waived by his guilty plea. The plea was vacated, in the interest of justice, on that ground:

Although defendant’s challenge to the plea was not preserved through an appropriate postallocution motion … , we exercise our interest of justice jurisdiction to reverse the judgment … . “While there is no mandatory catechism required of a pleading defendant, there must be an affirmative showing on the record that the defendant waived his or her constitutional rights” … .

Here, County Court made no effort to explain the consequences of a guilty plea, making only a passing reference to them by asking defendant if anyone was forcing him to give up his “right[] to [a] jury trial” … . The court further failed to establish that defendant had consulted with his counsel about the trial-related rights that he was forfeiting by pleading guilty or the constitutional consequences of a guilty plea, “instead making a vague inquiry into whether defendant had spoken to defense counsel” … or had any questions of his counsel regarding his “rights,” “the plea bargain, the trial and anything else that [was] important to [him]” … . With no affirmative showing on the record that defendant understood and waived his constitutional rights when he entered the guilty plea, the plea was invalid and must be vacated … . People v Herbert, 2017 NY Slip Op 01408, 3rd Dept 2-23-17

CRIMINAL LAW (ALTHOUGH DEFECTS IN GUILTY PLEA NOT PRESERVED BY A MOTION, PLEA VACATED IN THE INTEREST OF JUSTICE BECAUSE JUDGE DID NOT ENSURE DEFENDANT UNDERSTOOD THE CONSTITUTIONAL RIGHTS HE WAS GIVING UP)/GUILTY PLEA (ALTHOUGH DEFECTS IN GUILTY PLEA NOT PRESERVED BY A MOTION, PLEA VACATED IN THE INTEREST OF JUSTICE BECAUSE JUDGE DID NOT ENSURE DEFENDANT UNDERSTOOD THE CONSTITUTIONAL RIGHTS HE WAS GIVING UP)

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TRIAL JUDGE’S EXTENSIVE QUESTIONING OF WITNESSES DEPRIVED DEFENDANT OF A FAIR TRIAL.

The Second Department ordered a new trial because the trial judge conducted extensive questioning of witnesses:

Supreme Court conducted excessive and prejudicial questioning of trial witnesses, warranting a new trial. Although defense counsel did not object to the questioning of witnesses by the court, we reach this contention in the exercise of our interest of justice jurisdiction …. . “[W]hile a trial judge may intervene in a trial to clarify confusing testimony and facilitate the orderly and expeditious progress of the trial, the court may not take on the function or appearance of an advocate'” … . “In last analysis, [the trial judge] should be guided by the principle that his [or her] function is to protect the record, not to make it” … . “[T]he line is crossed when the judge takes on either the function or appearance of an advocate at trial” … . Indeed, “even proper questions from trial judges present significant risks of prejudicial unfairness, particularly when the trial judge indulge[s] in an extended questioning’ of witnesses” … .

* * * …[T]he court’s improper interference with the conduct of the trial deprived the defendant of a fair trial, and a new trial is warranted … . People v Davis, 2017 NY Slip Op 01381, 2nd Dept 2-22-17

 

CRIMINAL LAW (TRIAL JUDGE’S EXTENSIVE QUESTIONING OF WITNESSES DEPRIVED DEFENDANT OF A FAIR TRIAL)/JUDGES (CRIMINAL LAW, TRIAL JUDGE’S EXTENSIVE QUESTIONING OF WITNESSES DEPRIVED DEFENDANT OF A FAIR TRIAL)

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NO PROOF DEFENDANT INTENDED TO PERMANENTLY, AS OPPOSED TO TEMPORARILY, DEPRIVE COMPLAINANT OF POSSESSION OF HIS CAR, ATTEMPTED ROBBERY CONVICTIONS REVERSED.

The Second Department reversed defendant’s attempted robbery convictions as against the weight of the evidence. Defendant, covered in blood, approached the complainant’s car, asked to be taken to the hospital, and then tried to open the car door. That proof was insufficient to demonstrate larcenous intent, which is the intent to permanently deprive someone of his or her property:

“In order to sustain a conviction for robbery . . . the People must establish that defendant had the requisite intent—that is, larcenous intent. Larcenous intent means the intent to deprive another of property or to appropriate the same to himself or to a third person'” … . The terms “deprive” and “appropriate” are specifically defined in Penal Law § 155.00(3) and (4), respectively, and connote a purpose “to exert permanent or virtually permanent control over the property taken, or to cause permanent or virtually permanent loss to the owner of the possession and use thereof” … . Thus, “[t]he mens rea element of larceny . . . is simply not satisfied by an intent temporarily to use property without the owner’s permission, or even an intent to appropriate outright the benefits of the property’s short-term use” … . People v Terranova, 2017 NY Slip Op 01390, 2nd Dept 2-22-17

CRIMINAL LAW (NO PROOF DEFENDANT INTENDED TO PERMANENTLY DEPRIVE COMPLAINANT OF POSSESSION OF HIS CAR, ATTEMPTED ROBBERY CONVICTIONS REVERSED)/EVIDENCE (CRIMINAL LAW, ROBBERY, NO PROOF DEFENDANT INTENDED TO PERMANENTLY DEPRIVE COMPLAINANT OF POSSESSION OF HIS CAR, ATTEMPTED ROBBERY CONVICTIONS REVERSED)/LARCENOUS INTENT (CRIMINAL LAW, ROBBERY, NO PROOF DEFENDANT INTENDED TO PERMANENTLY DEPRIVE COMPLAINANT OF POSSESSION OF HIS CAR, ATTEMPTED ROBBERY CONVICTIONS REVERSED)/ROBBERY (NO PROOF DEFENDANT INTENDED TO PERMANENTLY DEPRIVE COMPLAINANT OF POSSESSION OF HIS CAR, ATTEMPTED ROBBERY CONVICTIONS REVERSED)

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WRIT OF PROHIBITION PROPER REMEDY FOR TRIAL COURT’S ERRONEOUS EVIDENTIARY RULING, COLLATERAL ESTOPPEL DOCTRINE SHOULD NOT HAVE BEEN APPLIED TO PRECLUDE EVIDENCE IN THIS CRIMINAL CASE.

The First Department, in a full-fledged opinion by Justice Gische, determined the trial court should not have applied the collateral estoppel doctrine to preclude the People from introducing evidence the defendant used a firearm to threaten the robbery victim. The grand jury dismissed the robbery first count and indicted on robbery third. The trial court reasoned that the grand jury necessarily found the defendant did not have a weapon by refusing to indict on robbery first. The First Department held: (1) the article 78 proceeding seeking a writ of prohibition (brought by the People against the trial judge) was the appropriate remedy; and (2) the trial judge is prohibited from enforcing the order precluding evidence of the defendant’s possession of a weapon:

A writ of prohibition is an extraordinary remedy, only available to prevent a court from either acting without jurisdiction or in excess of its authorized powers in a proceeding over which it otherwise has jurisdiction … . Prohibition is not available to review mere errors of law, even when the errors are truly egregious … .

“Although the distinction between legal errors and actions made in excess of authority is not always easily made, abuses of power may be identified by their impact on the entire proceeding as distinguished from an error in a proceeding itself” … . The trial court’s ruling in this case was an error that affected the entire proceeding and thus constituted an excess of the court’s authority. The ruling prevents the People from proving the element of force required under third degree robbery because the gun was the only evidence of force that was presented to the grand jury. The People cannot present different facts at trial in support of the indictment … . Although the court did not actually dismiss the third degree robbery charge, the charge cannot withstand a claim of legal insufficiency, because there are no other facts on which the prosecution can rely to prove force, a necessary element of the charge. * * *

A writ of prohibition will lie where a trial court’s erroneous ruling affects the proceeding in a conclusive manner, by terminating the case … . At bar, although the ruling did not actually terminate the case, it effectively terminated the ability of the People to prosecute the highest count in the indictment … . We therefore find that the court’s ruling is reviewable by way of a writ of prohibition. * * *

The Court of Appeals has recognized … that for policy reasons collateral estoppel is not as liberally applied in criminal prosecutions as in civil actions … . The rigid application of collateral estoppel must yield to society’s preeminent and overwhelming interest in ensuring the correctness of determinations of guilt or innocence … . “Thus, if … collateral estoppel ‘cannot practicably be followed if a necessary witness is to give truthful testimony, then [the doctrine] should not be applied'” … . Matter of Clark v Newbauer, 2017 NY Slip Op 01326, 1st Dept 2-21-17

 

CRIMINAL LAW (WRIT OF PROHIBITION PROPER REMEDY FOR TRIAL COURT’S ERRONEOUS EVIDENTIARY RULING, COLLATERAL ESTOPPEL DOCTRINE SHOULD NOT HAVE BEEN APPLIED TO PRECLUDE EVIDENCE IN THIS CRIMINAL CASE)/CIVIL PROCEDURE (WRIT OF PROHIBITION PROPER REMEDY FOR TRIAL COURT’S ERRONEOUS EVIDENTIARY RULING, COLLATERAL ESTOPPEL DOCTRINE SHOULD NOT HAVE BEEN APPLIED TO PRECLUDE EVIDENCE IN THIS CRIMINAL CASE)/EVIDENCE (CRIMINAL LAW, WRIT OF PROHIBITION PROPER REMEDY FOR TRIAL COURT’S ERRONEOUS EVIDENTIARY RULING, COLLATERAL ESTOPPEL DOCTRINE SHOULD NOT HAVE BEEN APPLIED TO PRECLUDE EVIDENCE IN THIS CRIMINAL CASE)/JUDGES (CRIMINAL LAW, WRIT OF PROHIBITION PROPER REMEDY FOR TRIAL COURT’S ERRONEOUS EVIDENTIARY RULING, COLLATERAL ESTOPPEL DOCTRINE SHOULD NOT HAVE BEEN APPLIED TO PRECLUDE EVIDENCE IN THIS CRIMINAL CASE)/PROHIBITION (CRIMINAL LAW, WRIT OF PROHIBITION PROPER REMEDY FOR TRIAL COURT’S ERRONEOUS EVIDENTIARY RULING, COLLATERAL ESTOPPEL DOCTRINE SHOULD NOT HAVE BEEN APPLIED TO PRECLUDE EVIDENCE IN THIS CRIMINAL CASE)/COLLATERAL ESTOPPEL (CRIMINAL LAW, WRIT OF PROHIBITION PROPER REMEDY FOR TRIAL COURT’S ERRONEOUS EVIDENTIARY RULING, COLLATERAL ESTOPPEL DOCTRINE SHOULD NOT HAVE BEEN APPLIED TO PRECLUDE EVIDENCE IN THIS CRIMINAL CASE)

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MIRANDA WARNINGS AND 710.30 NOTICE NOT REQUIRED; DEFENDANT’S STATEMENT HE RESIDED AT THE APARTMENT WHERE CONTRABAND WAS FOUND WAS IN RESPONSE TO PEDIGREE QUESTIONS.

The First Department determined the defendant’s statement that he lived in the apartment which was searched and where contraband was found did not require Miranda warnings or a 710.30 notice:

Neither Miranda warnings nor CPL 710.30(1)(a) notice was required with respect to defendant’s statement, in response to a detective’s pedigree question, that his residence was the apartment where the police had executed a search warrant and discovered contraband. The detective’s routine administrative questioning was not designed to elicit an incriminating response … , even if the answer was reasonably likely to be incriminating … . People v Martin, 2017 NY Slip Op 01309, 1st Dep 2-21-17

 

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FIVE HOUR BREAK SUFFICIENT TO DISSIPATE EFFECT OF THE MIRANDA VIOLATION.

The First Department determined Supreme Court properly denied suppression of the February 5th statement, as well as the first portion of the July 11th videotaped statement by the defendant, despite the suppression of statements made five or six hours earlier on July 11. The videotaped statement was deemed sufficiently attenuated from the inadmissible statements:

Defendant’s videotaped statement was made approximately five hours after the initial Miranda violation. Much shorter breaks have been found sufficient to dissipate the taint of a Miranda violation … . In addition, “defendant had demonstrated an unqualified desire to speak” … , seemed alert and relaxed in the video, and did not appear nervous or intimidated. Indeed, he was even “laughing on occasion.”

Defendant had been Mirandized after his first encounter with the police concerning the case, on February 5. Further, the ADA — who had not participated in the earlier interrogation — was the sole questioner in the admitted portion of the video. Although two of the detectives who had conducted the earlier interrogation were present, they did not participate in the questioning in the admitted segment. Notably, the court suppressed any references to the suppressed statements made earlier on July 11th, as well as the later portion of the video in which the detectives participated in questioning … . People v Richardson, 2017 NY Slip Op 01304, 1st Dept 2-21-17

 

CRIMINAL LAW (FIVE HOUR BREAK SUFFICIENT TO DISSIPATE EFFECT OF THE MIRANDA VIOLATION)/EVIDENCE (CRIMINAL LAW, FIVE HOUR BREAK SUFFICIENT TO DISSIPATE EFFECT OF THE MIRANDA VIOLATION)/SUPPRESSION (CRIMINAL LAW, FIVE HOUR BREAK SUFFICIENT TO DISSIPATE EFFECT OF THE MIRANDA VIOLATION)/MIRANDA VIOLATION (CRIMINAL LAW, FIVE HOUR BREAK SUFFICIENT TO DISSIPATE EFFECT OF THE MIRANDA VIOLATION)/STATEMENTS (CRIMINAL LAW, FIVE HOUR BREAK SUFFICIENT TO DISSIPATE EFFECT OF THE MIRANDA VIOLATION)

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THREATENING TO CALL SOMEONE TO HAVE VICTIM BEATEN UP MET THE THREAT OF IMMEDIATE USE OF PHYSICAL FORCE ELEMENT OF ROBBERY.

The First Department, in a full-fledged opinion by Justice Acosta, determined the evidence was sufficient to support defendant’s robbery second and grand larceny fourth convictions. Defendant told the victim (Diaz) she would have him beaten up if he didn’t give her $20. The court held the victim had been threatened with immediate use of force within the meaning of the statute:

With respect to defendant’s robbery conviction, the evidence demonstrates that defendant threatened Diaz with the immediate use of physical force. Pursuant to Penal Law § 160.00(1), a person is guilty of robbery “when, in the course of committing a larceny, he uses or threatens the immediate use of physical force upon another person for the purpose of . . . [p]reventing or overcoming resistance to the taking of the property or to the retention thereof immediately after the taking.” However, “[t]he statute does not require the use of any words whatsoever, but merely that there be a threat, whatever its nature, of the immediate use of physical force” … . There is also no requirement that a weapon be displayed or that the victim be physically injured to demonstrate that there was a threat of immediate physical force … . Further, the threat of the immediate use of force may be demonstrated by “a chain of actions on the part of [the] defendant” … .

Diaz testified that he gave defendant the $20 because he was “scared” after defendant … prevented him from leaving and defendant explicitly threatened him that if he did not comply, her boyfriend would beat him up. Defendant then went to speak to a man who gestured that he was going to call someone … . People v Villanueva, 2017 NY Slip Op 01299, 1st Dept 2-16-17

 

CRIMINAL LAW (THREATENING TO CALL SOMEONE TO HAVE VICTIM BEATEN UP MET THE THREAT OF IMMEDIATE USE OF PHYSICAL FORCE ELEMENT OF ROBBERY)/EVIDENCE (CRIMINAL LAW, THREATENING TO CALL SOMEONE TO HAVE VICTIM BEATEN UP MET THE THREAT OF IMMEDIATE USE OF PHYSICAL FORCE ELEMENT OF ROBBERY)/ROBBERY (THREATENING TO CALL SOMEONE TO HAVE VICTIM BEATEN UP MET THE THREAT OF IMMEDIATE USE OF PHYSICAL FORCE ELEMENT OF ROBBERY)/THREAT (ROBBERY, THREATENING TO CALL SOMEONE TO HAVE VICTIM BEATEN UP MET THE THREAT OF IMMEDIATE USE OF PHYSICAL FORCE ELEMENT OF ROBBERY)/IMMEDIATE USE OF PHYSICAL FORCE (ROBBERY, THREATENING TO CALL SOMEONE TO HAVE VICTIM BEATEN UP MET THE THREAT OF IMMEDIATE USE OF PHYSICAL FORCE ELEMENT OF ROBBERY)

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VICTIM’S IDENTIFICATION TESTIMONY WAS SUFFICIENT TO SUPPORT CONVICTION, DESPITE LOSS OF CONSCIOUSNESS, DIZZINESS AND INCONSISTENCIES.

The First Department, over an extensive dissent, determined the identification testimony by the assault victim was credible, despite a period of unconsciousness, dizziness and inconsistencies:

[The] grounds for undercutting one-witness identifications [in other cases] are not comparable to the dizziness and loss of consciousness caused by the subject assault, and the limited nature of the complainant’s two opportunities to look directly at his attacker. Our system of criminal justice relies on victims of violence identifying their attackers when they are able to do so. It would be ironic indeed if the severity of an attack and the resulting injuries were to prompt courts to treat the subsequent identification as unworthy of belief, despite the complainant’s certainty. Of course, the defense is entitled to question an identification based on the complainant’s compromised condition caused by the attack. However, that argument did not sway the jury here, and upon our review of the evidence at trial, it does not appear that the complainant was unable to make an identification.

Any inconsistencies in the complainant’s testimony were minor, possibly due to limitations in his English skills, and did not undermine his overall credibility. People v Kahson B., 2017 NY Slip Op 01265, 1st Dept 2-16-17

 

CRIMINAL LAW (VICTIM’S IDENTIFICATION TESTIMONY WAS SUFFICIENT TO SUPPORT CONVICTION, DESPITE LOSS OF CONSCIOUSNESS, DIZZINESS AND INCONSISTENCIES)/EVIDENCE (CRIMINAL LAW, VICTIM’S IDENTIFICATION TESTIMONY WAS SUFFICIENT TO SUPPORT CONVICTION, DESPITE LOSS OF CONSCIOUSNESS, DIZZINESS AND INCONSISTENCIES)/IDENTIFICATION (CRIMINAL LAW, EVIDENCE, VICTIM’S IDENTIFICATION TESTIMONY WAS SUFFICIENT TO SUPPORT CONVICTION, DESPITE LOSS OF CONSCIOUSNESS, DIZZINESS AND INCONSISTENCIES)

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