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THE PEOPLE’S STATEMENTS OF READINESS FOR TRIAL WERE DEEMED ILLUSORY; CASE DISMISSED ON SPEEDY TRIAL GROUNDS.

The First Department, over an extensive dissent, determined the People’s two statements of readiness (for trial) were illusory. The defendant’s case should have been dismissed on speedy trial grounds:

 

First, the People provided no explanation why, after filing and serving the certificate of readiness on August 30, 2011, shortly after defendant’s arraignment on August 25, 2011, they answered not ready at the next court date on September 7, 2011 … . Nothing in the record, express or inferred, explains their change in status from ready to not ready. As the People “gave no explanation for the change in circumstances between the initial statement of readiness and the subsequent admission that the People were not ready to proceed,” and the statement of readiness thus “did not accurately reflect the People’s position,” the People should have been charged with the entire period, a total of 70 days … . The People argue that the court did not ask for any reason, but the burden rests on the People to clarify, on the record, the basis for the adjournment … .

Second, after the People answered not ready on January 31, 2012, because the prosecutor was on trial in another case, the matter was adjourned to March 20, 2012. On February 7, 2012, the People filed and served a certificate of readiness. At the next court date, March 20, 2012, however, they again answered not ready because the prosecutor was on trial in another case. The court properly deemed the entire period chargeable to the People, “notwithstanding” the February 7, 2012 certificate of readiness, but should have also charged subsequent adjournments to the People. If the prosecutor was on trial at the prior and subsequent adjournments, it is unclear why the People filed and served an off-calendar certificate of readiness, or whether the prosecutor was on trial in the same or a different case. As a result, the February 7, 2012 certificate of readiness was illusory, and the entirety of subsequent adjournment periods (not merely the number of days the People requested), until the People next announced that they were ready, should have been charged to them. Specifically, the 50 days from March 20, 2012 until May 9, 2012, 61 days from May 9, 2012 to July 9, 2012, and 52 days from July 9, 2012, until August 30, 2012, when the People validly declared their readiness, should have been charged. People v Rodriguez, 2016 NY Slip Op 00423, 1st Dept 1-21-16

 

CRIMINAL LAW (SPEEDY TRIAL, PEOPLE’S STATEMENTS OF READINESS DEEMED ILLUSORY)/SPEEDY TRIAL (PEOPLE’S STATEMENTS OF READINESS DEEMED ILLUSORY)/STATEMENT OR READINESS (SPEEDY TRIAL, STATEMENTS OF READINESS DEEMED ILLUSORY)

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WHERE THE EVIDENCE OF GUILT WAS NOT OVERWHELMING, COUNTY COURT’S ERROR IN ALLOWING EVIDENCE AT TRIAL WHICH THE COURT HAD PREVIOUSLY PRECLUDED REQUIRED REVERSAL AND A NEW TRIAL.

The Third Department determined it was reversible error to allow a police officer’s testimony identifying defendant as a person depicted in surveillance video from a store about an hour before the robbery of which defendant was convicted. Defendant claimed he was shopping in the store at the time of the robbery. The evidence of defendant’s participation in the robbery was not overwhelming. The trial judge had ruled the video could be introduced in evidence but no testimony identifying the defendant as a person depicted in the video could be offered. At trial, however, over objection, Cornell, a police officer, was permitted to identify the defendant in the video:

 

… [E]arlier in the proceedings County Court had ruled that, to the extent that the People were going to offer such surveillance footage into evidence, they were precluded from offering testimony identifying defendant in such footage. Cornell then testified on direct examination that he obtained the video surveillance footage from the store where defendant had claimed to have been shopping at the time of the robbery and described a group of five people that entered at approximately 6:20 p.m. and left at approximately 6:45 p.m., approximately one hour before the robbery. Upon the People’s question, “And the group being [defendant], three women and a toddler,” Cornell answered, “That’s correct.” Defendant objected to the question and the answer, which was overruled by County Court. Inasmuch as this testimony violated County Court’s prior ruling because it identified defendant as being the individual in the video who was accompanied by three women and a toddler, it should have been precluded.

Based upon the record before us, County Court’s evidentiary error in permitting Cornell’s identification testimony of defendant in the surveillance video cannot be deemed harmless. Specifically, under the particular factual circumstances of this case, the evidence of defendant’s guilt, although legally sufficient to support the jury’s verdict, was not overwhelming given the lack of direct evidence linking defendant to the crime and the conflicting witness testimony regarding defendant’s presence at the crime scene … . People v Myrick, 2016 NY Slip Op 00217, 3rd Dept 1-14-16

 

CRIMINAL LAW (WHERE THE EVIDENCE OF GUILT WAS NOT OVERWHELMING, ALLOWING EVIDENCE AT TRIAL WHICH HAD BEEN PREVIOUSLY PRECLUDED WAS REVERSIBLE ERROR)/EVIDENCE (WHERE THE EVIDENCE OF GUILT WAS NOT OVERWHELMING, ALLOWING EVIDENCE AT TRIAL WHICH HAD BEEN PREVIOUSLY PRECLUDED WAS REVERSIBLE ERROR)

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SUPPRESSION OF JUVENILE’S PROVIDING FALSE NAME AND DATE OF BIRTH TO POLICE OFFICER PROPERLY DENIED; JUVENILE DELINQUENCY ADJUDICATION BASED UPON THE FALSE PEDIGREE INFORMATION PROPER.

The First Department, over an extensive dissent, determined suppression of the juvenile’s giving a false name and date of birth when asked for that information by a police officer was properly denied. The juvenile was warned by the officer that providing false pedigree information would result in a false personation charge (a class B misdemeanor). The juvenile was in fact found to have committed an act which, if committed by an adult, would constitute false personation. The court further determined the sentence of probation was the least restrictive alternative consistent with the juvenile’s needs. The dissent focused on the propriety of the sentence. With respect to the denial of the suppression motion, the court explained:

The court properly denied appellant’s motion to suppress her statement to the police, in which she gave a false name and date of birth, resulting in the false personation charge (Penal Law § 190.23). The police had probable cause to believe appellant was a runaway … . The then 14-year-old appellant, who appeared to be as young as 13, was alone in a PATH station in New Jersey, but she vaguely claimed to live in “upstate” New York. In addition, she had a bruised eye and was wearing provocative clothing, suggesting the possibility of some kind of sexual exploitation. The police were entitled to ask pedigree questions without Miranda warnings, even though an officer warned appellant, as required by the false personation statute, that providing false information would result in an additional charge … . Matter of Christy C., 2016 NY Slip Op 00095, 1st Dept 1-12-16

 

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THE SEXUAL ASSAULT REFORM ACT (SARA), WHICH PROHIBITS CERTAIN SEX OFFENDERS FROM RESIDING OR TRAVELING WITHIN 1000 FEET OF A SCHOOL, DOES NOT IMPOSE PUNISHMENT AND THEREFORE DOES NOT VIOLATE THE EX POST FACTO CLAUSE.

The First Department, in an extensive opinion by Justice Gische, over a dissenting opinion by Justice Kapnick, determined the Sexual Assault Reform Act (SARA), which prohibits certain sex offenders, including appellant, from residing or traveling within 1000 feet of school grounds, did not violate the federal or state constitutions. Appellant claimed there was no place he could reside in Manhattan, and no way to travel to the places he was required to visit in Manhattan, without violating the statute. SARA was enacted after appellant’s conviction. Appellant argued the statute violated the prohibition against Ex Post Facto laws. The court applied the intent-effects analysis. If the intent of the legislation was to impose punishment, the statute would violate the EX Post Facto prohibition and the court’s inquiry would end. But if the intent was to establish civil proceedings, the court must go on to determine whether the effect of the statute is so punitive as to negate its civil nature. After an extensive analysis, the First Department held the statute was not intended to impose punishment, and the additional restrictions the statute imposed upon appellant, who was already otherwise restricted as a parolee, did not rise to the level of punishment:

 

… [W]hile some factors favor petitioner, overall we do not find the clear proof that is necessary to support a determination that SARA is punitive in its effect. The legislature was not “masking punitive provisions behind the veneer of a civil statute” … . Consequently, we conclude that SARA does not violate the Ex Post Facto Clause of the United States Constitution. Matter of Williams v Department of Corr. & Community Supervision, 2016 NY Slip Op 00135, 1st Dept 1-12-16

 

CRIMINAL LAW (SEXUAL ASSAULT REFORM ACT DOES NOT VIOLATE EX POST FACTO CLAUSE)/SEXUAL ASSAULT REFORM ACT [SARA] (1000-FOOT SCHOOL-GROUNDS NO-GO ZONE IS NOT PUNITIVE IN EFFECT AND DOES NOT VIOLATE EX POST FACTO CLAUSE)/CONSTITUTIONAL LAW (1000-FOOT SCHOOL-GROUNDS NO-GO ZONE IN THE SEXUAL ASSAULT REFORM ACT IS NOT PUNITIVE IN EFFECT AND THEREFORE DOES NOT VIOLATE EX POST FACTO CLAUSE)/EX POST FACTO CLAUSE (1000-FOOT SCHOOL-GROUNDS NO-GO ZONE IN THE SEXUAL ASSAULT REFORM ACT IS NOT PUNITIVE IN EFFECT AND THEREFORE DOES NOT VIOLATE EX POST FACTO CLAUSE)

DENIAL OF PAROLE WAS IRRATIONAL; PETITIONER’S PRISON RECORD WAS EXCEPTIONAL UNTIL HIS MEDICATION FOR TREATMENT OF SCHIZOPHRENIA WAS STOPPED.

The Third Department affirmed Supreme Court’s annulment of the Board of Parole’s denial of petitioner’s request for release on parole. Petitioner’s record in prison was exceptional except for a four-month period during which his medication to treat schizophrenia was stopped. Once medication resumed, petitioner once again functioned well:

 

The Board is charged with considering whether “there is a reasonable probability that, if [an] inmate is released, he [or she] will live and remain at liberty without violating the law, and that his [or her] release is not incompatible with the welfare of society and will not so deprecate the seriousness of his [or her] crime as to undermine respect for the law” (Executive Law § 259-i [2] [c] [A]). “The decision to grant parole release is discretionary, but the Board is required to consider certain guidelines in making its determination” … . These guidelines include such factors as the inmate’s institutional record, his or her release plans, the seriousness of the offense, and his or her prior criminal record (see Executive Law § 259-i [2] [c] [A] [i], [iii], [vii], [viii]; 9 NYCRR 8002.3 [a] [1], [3], [7], [8]). In 2011, the law was amended to further require that the Board’s “review must include an instrument that measures rehabilitation and the likelihood of success on parole” (… see Executive Law §§ 259-c [4]; 259-i [2] [c]). The Board utilizes the COMPAS assessment to satisfy this requirement … . * * *

Considering this factual background, we agree with Supreme Court that the Board’s determination was irrational … . Further, it was irrational to such a degree that it cannot withstand judicial scrutiny, despite the very limited scope of our review (see Executive Law § 259-i [5]…). As petitioner argues, a fair review of this record compels the conclusion that the determination to remove him from all medication for his mental illness led to a psychotic breakdown that rendered him unable to comply with prison regulations during the period when the disciplinary infractions occurred. To withhold petitioner’s necessary medications was apparently an error of medical judgment. However, for the Board to then rely upon petitioner’s conduct during the psychotic crisis that was thus precipitated as a primary ground for denying his release is so inherently unfair and unreasonable that it meets the high standard of “irrationality bordering on impropriety” warranting our intervention … . To hold otherwise would, in effect, result in punishing petitioner with continued incarceration for the failure of prison officials to provide him with proper treatment for his mental illness — a result that we cannot sanction. Accordingly, we agree with Supreme Court that petitioner must be afforded a de novo hearing before the Board. Matter of Hawthorne v Stanford, 2016 NY Slip Op 00083, 3rd Dept 1-7-16

 

 

CRIMINAL LAW (DENIAL OF PAROLE BASED ON BEHAVIOR WHEN PETITIONER WAS DENIED MEDICATION FOR SCHIZOPHRENIA WAS IRRATIONAL)/PAROLE (DENIAL OF PAROLE BASED ON BEHAVIOR WHEN PETITIONER WAS DENIED MEDICATION FOR SCHIZOPHRENIA WAS IRRATIONAL)/MENTAL ILLNESS (DENIAL OF PAROLE BASED ON BEHAVIOR WHEN PETITIONER WAS DENIED MEDICATION FOR SCHIZOPHRENIA WAS IRRATIONAL)

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DEFENSE COUNSEL’S FAILURE TO MOVE TO REOPEN SUPPRESSION HEARING BASED ON NEW EVIDENCE LEARNED AT TRIAL CONSTITUTED INEFFECTIVE ASSISTANCE.

The First Department, over an extensive dissent, determined defense counsel was ineffective for failing to move to reopen the suppression hearing. Defendant was convicted of burglary. A bag of tools was the subject of a suppression motion. At the suppression hearing, the police officer testified the bag was open at defendant’s feet. The suppression court ruled the “burglar’s tools” were properly seized under the “plain view” exception to the warrant requirement. At trial, the building superintendent who stopped the defendant testified the bag was in defendant’s hand and closed when the police arrived. Based on that new information, defense counsel should have requested the reopening of the suppression hearing:

 

Under CPL 710.40(4), a suppression hearing may be reopened upon a showing that the defendant has discovered “additional pertinent facts” that “could not have [been] discovered with reasonable diligence before the determination of the motion.” Here, the additional facts were “pertinent” because the superintendent’s testimony, if credited, would have undermined the ruling that the tools were admissible because they were in plain view. This was not a minor or routine inconsistency; the superintendent’s version was completely at odds with a plain view theory. Any issue of whose recollection was most reliable should have been presented to the hearing court. People v Kindell, 2016 NY Slip Op 00027, 1st Dept 1-7-16

 

CRIMINAL LAW (INEFFECTIVE ASSISTANCE, FAILURE TO REOPEN SUPPRESSION HEARING BASED ON NEW EVIDENCE)/EVIDENCE (INEFFECTIVE ASSISTANCE, FAILURE TO REOPEN SUPPRESSION HEARING BASED ON NEW EVIDENCE)/ATTORNEYS (INEFFECTIVE ASSISTANCE, FAILURE TO REOPEN SUPPRESSION HEARING BASED ON NEW EVIDENCE)/INEFFECTIVE ASSISTANCE (FAILURE TO REOPEN SUPPRESSION HEARING BASIED ON NEW EVIDENCE)/SUPPRESSION (INEFFECTIVE ASSISTANCE, FAILURE TO REOPEN SUPPRESSION HEARING BASED ON NEW EVIDENCE)

COUNTY COURT ABUSED ITS DISCRETION WHEN IT DENIED DEFENDANT’S APPLICATION FOR JUDICIAL DIVERSION TO A DRUG TREATMENT PROGRAM.

The Third Department, reversing County Court, determined defendant was eligible for judicial diversion to a drug treatment program. Defendant was stopped with four pounds of marijuana in his car. He demonstrated he was addicted to marijuana, that drug-dependence was a contributing factor re: his criminal behavior, and this was his first contact with the criminal justice system:

 

It is undisputed that defendant is an eligible defendant as defined in CPL 216.00 (1) and that his incarceration was not necessary to protect the public. Contrary to the determination of County Court, however, we also find that the uncontroverted evidence in the record amply supports the conclusions that defendant has a history of substance abuse and that such substance abuse and dependence were contributing factors to his criminal behavior. Specifically, among other things, defendant described that his progressively escalating marihuana use, which began socially at age 14, advanced to daily use over the ensuing years and culminated in defendant becoming a mule, transporting larger quantities of marihuana across state lines for other individuals in order to receive compensation in the form of marihuana. Defendant attested to resorting to this conduct when supporting his habit became too expensive, despite his gainful employment. We also note the expert testimony of a substance abuse counselor who opined that, based upon his history, defendant was an addict who was cannabis dependent.

Inasmuch as “[t]he statute does not require that a defendant’s . . . substance abuse or dependence be the exclusive or primary cause of the defendant’s criminal behavior” … , but instead only requires it be a contributing factor, we find no basis for County Court’s determination that the instant arrest — i.e., defendant’s only involvement with the criminal justice system — was not contributed to by defendant’s marihuana use. People v Cora, 2016 NY Slip Op 00066, 3rd Dept 1-7-15

 

 

 

 

 

 

CRIMINAL LAW (APPLICATION FOR JUDICIAL DIVERSION TO A DRUG TREATMENT PROGRAM SHOULD HAVE BEEN GRANTED)/JUDICIAL DIVERSION (APPLICATION FOR DIVERSION TO A DRUG TREATMENT PROGRAM SHOULD HAVE BEEN GRANTED)/DRUG TREATMENT PROGRAM (JUDICIAL DIVERSION APPLICATION SHOULD HAVE BEEN GRANTED)/MARIJUANA (APPLICATION FOR JUDICIAL DIVERSION TO A DRUG TREATMENT PROGRAM SHOULD HAVE BEEN GRANTED)

COCAINE-POSSESSION OFFENSES CHARGED IN THE SUPERIOR COURT INFORMATION (SCI) WERE NOT LESSER INCLUDED OFFENSES OF THE THE COCAINE-POSSESSION OFFENSE CHARGED IN THE FELONY COMLAINTS; SCI IS JURISDICTIONALLY DEFECTIVE.

The Third Department determined the superior court informations (SCI’s) to which defendant pled guilty were jurisdictionally defective because neither SCI charged a lesser included offense of the offense charged in the original felony complaints. If it is possible, under any set of facts, to commit the greater offense but not the lesser, the lesser is not a lesser included offense. The offenses at issue here involved the possession of cocaine:

“A crime is a lesser included offense of a charge of a higher degree only when in all circumstances, not only in those presented in the particular case, it is impossible to commit the greater crime without concomitantly, by the very same conduct, committing the lesser offense” … . To be guilty of the offense charged in the SCI, a defendant must attempt to “knowingly and unlawfully possess cocaine” that weighs “[500] milligrams or more” (Penal Law §§ 110.00, 220.06 [5]). The first felony complaint charged defendant with criminal possession of a controlled substance in the third degree, which requires proof of knowing, unlawful possession of substances containing narcotic drugs that have “an aggregate weight of one-half ounce or more” (Penal Law § 220.16 [12]). Considered in the abstract, it is possible to possess or attempt to possess one-half ounce of a mixture of cocaine and some other substance in which the proportion of cocaine is less than 500 milligrams. Thus, it is possible to commit criminal possession of a controlled substance in the third degree without also committing attempted criminal possession of a controlled substance in the fifth degree, and the offense charged in the SCI is not a lesser included offense of the crime charged in the first felony complaint.

The second felony complaint charged defendant with criminal possession of a controlled substance in the fifth degree, which is committed when a person “knowingly and unlawfully possesses a controlled substance with intent to sell it” (Penal Law § 220.06 [1]). It is possible to possess cocaine with the intent to sell it while not concurrently possessing cocaine weighing more than 500 milligrams, or attempting to do so, as required to commit the crime charged in the SCI (see Penal Law §§ 110.00, 220.06 [5]). Thus, the crime charged in the SCI is not a lesser included offense of the crime charged in the second felony complaint … . People v Seals, 2016 NY Slip Op 00065, 3rd Dept 1-7-16

CRIMINAL LAW (SUPERIOR COURT INFORMATION JURISDICTIONALLY DEFECTIVE, OFFENSES WERE NOT LESSER INCLUDEDS)/SUPERIOR COURT INFORMATIONS (JURISDICTIONALLY DEFECTIVE, OFFENSES NOT LESSER INCLUDEDS)/COCAINE OFFENSES (SUPERIOR COURT INFORMATION JURISDICTIONALLY DEFECTIVE, OFFENSES NOT LESSER INCLUDEDS)

PEOPLE SHOULD HAVE INSTRUCTED THE GRAND JURY ON THE AGENCY DEFENSE IN THIS CRIMINAL SALE OF MARIJUANA CASE, INDICTMENT PROPERLY DISMISSED.

The Third Department determined County Court properly reinspected the grand jury minutes pursuant to a second motion by defense counsel and properly dismissed the indictment because the People failed to instruct the grand jury on an applicable defense. Because the first motion to inspect argued the evidence before the grand jury was insufficient, the law of the case doctrine did not prohibit the second motion, which argued the proceedings were defective. The defendant was charged with criminal sale of marijuana.  However, the facts supported the theory the defendant was acting as an agent for the buyer:

 

… [W]hile there is no requirement that the grand jury “be charged with every potential defense suggested by the evidence” … , the People “must charge . . . those defenses that the evidence will reasonably support” … . As this Court recently reiterated, “[u]nder the agency doctrine, a person who acts solely as the agent of a buyer in procuring drugs for the buyer is not guilty of selling the drug to the buyer, or of possessing it with intent to sell it to the buyer. Whether the defendant was a seller, or merely a purchaser doing a favor for a friend, is generally a factual question [to be resolved] . . . based upon [considerations of] factors such as the relationship between the buyer and the defendant, who initiated the transaction, whether the defendant had previously engaged in drug transfers and whether he or she profited from the sale” … . * * *

 

…. [T]he evidence before the grand jury reasonably supported the defense of agency; hence, the People’s failure to instruct the grand jury in this regard rendered that proceeding defective — particularly in view of the fact that the People were on notice of this potential defense prior to the commencement thereof. There is no question that it was the buyer who initiated the sale and, given the relationship between defendant and the buyer’s stepbrother, the evidence reasonably suggested that defendant was doing a favor for the stepsister of one of his friends. Additionally, none of the testimony offered before the grand jury revealed that defendant had a prior history of drug sales, and the evidence that defendant profited from the subject transaction was tenuous at best. Under these circumstances, County Court properly granted defendant’s motion to dismiss the indictment under CPL 210.35 (5) … . People v Gallo, 2016 NY Slip Op 00064, 3rd Dept 1-7-16

 

 

 

 

 

 

CRIMINAL LAW (GRAND JURY SHOULD HAVE BEEN INSTRUCTED ON AGENCY DEFENSE)/GRAND JURIES (PEOPLE SHOULD HAVE INSTRUCTED JURY ON AGENCY DEFENSE)/AGENCY DEFENSE (GRAND JURY SHOULD HAVE BEEN INSTRUCTED ON AGENCY DEFENSE)/MARIJUANA, CRIMINAL SALE (GRAND JURY SHOULD HAVE BEEN INSTRUCTED ON AGENCY DEFENSE)

ANONYMOUS 911 CALL COUPLED WITH POLICE OFFICER’S OBSERVATIONS PROVIDED REASONABLE SUSPICION JUSTIFYING DETENTION OF THE DEFENDANT.

The Fourth Department determined an anonymous 911 call combined with the police officer’s observations provided the officer with reasonable suspicion defendant had a weapon, justifying detention of the defendant:

 

Although “a radioed tip may have almost no legal significance when it stands alone, . . . when considered in conjunction with other supportive facts, it may thus collectively, although not independently, support a reasonable suspicion justifying intrusive police action” … . Here … that “additional support can … be provided by factors rapidly developing or observed at the scene” … . The evidence at the hearing established that ” the report of the 911 caller was based on the contemporaneous observation of conduct that was not concealed’ ” … . Upon the officer’s arrival, defendant was positioned at a bladed angle toward the officer with his hand in his waistband or sweatshirt pocket, ” common sanctuar[ies] for weapons’ ” … . …

“A police officer directed to a location by a general radio call cannot reasonably be instructed to close his eyes to reality—neither the officer nor justice should be that blind. The officer was rightfully and dutifully on the scene and could not ignore possible indications of criminality, nor is there any logical reason for him to reject the natural mental connection between newly encountered facts and the substance of the radio message. More importantly, there certainly is no justification for holding that an officer in such a situation cannot take note of a significant occurrence indicating a possible threat to his life, merely because the call which directed him to the scene was in and of itself an insufficient predicate for intrusive action against a particular person” … . In accordance with Court of Appeals’ precedent, we conclude that “it would be unrealistic to require [the responding officer], who had been told that [a] gunm[a]n might be present, to assume the risk that the defendant’s conduct was in fact innocuous or innocent. Such an assumption would be at odds with his reasonably acquired belief that he was in danger and his constitutionally authorized action . . . It would, indeed, be absurd to suggest that a police officer has to await the glint of steel before he can act to preserve his safety” … . People v Williams, 2016 NY Slip Op 00789, 4th Dept 2-5-16

 

CRIMINAL LAW (STATEMENTS AFTER ILLEGAL ARREST NOT SUPPRESSIBLE IF SUFFICIENTLY ATTENUATED)/EVIDENCE (STATEMENTS AFTER ILLEGAL ARREST NOT SUPPRESSIBLE IF SUFFICIENTLY ATTENUATED)/SUPPRESSION (STATEMENTS AFTER ILLEGAL ARREST NOT SUPPRESSIBLE IF SUFFICIENTLY ATTENUATED)

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