Muniz v. Roth

163 Misc. 2d 293, 620 N.Y.S.2d 700, 1994 N.Y. Misc. LEXIS 559
CourtNew York Supreme Court
DecidedNovember 21, 1994
StatusPublished

This text of 163 Misc. 2d 293 (Muniz v. Roth) is published on Counsel Stack Legal Research, covering New York Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Muniz v. Roth, 163 Misc. 2d 293, 620 N.Y.S.2d 700, 1994 N.Y. Misc. LEXIS 559 (N.Y. Super. Ct. 1994).

Opinion

OPINION OF THE COURT

Phillip R. Rumsey, J.

This CPLR article 78 proceeding was commenced to compel the respondent, Nelson E. Roth, Esq., to produce certain records and documents pursuant to Public Officers Law § 84 et seq., commonly called the Freedom of Information Law (FOIL).

The petitioner, Robert Muniz (the defendant in the case People v Muniz, Tompkins County, indictment No. 91-116), requested the respondent to produce defined records and documents related to the fabrication of fingerprint evidence in his case. The request was made through Muniz’ attorney by letter dated June 8, 1994. The respondent did not reply to the request within five business days as required under Public Officers Law § 89 (3) or at any time thereafter prior to the motion.

Nelson E. Roth, Esq. is presently serving as a New York [295]*295Special Prosecutor pursuant to Executive Orders Nos. 165 through 165.8 (9 NYCRR 4.165), and as a Deputy Attorney-General of the State of New York pursuant to the appointment of the Attorney-General of the State of New York in connection with the Governor’s Executive Orders. His responsibilities relate specifically to the investigation of allegations that employees or former employees of the Division of the New York State Police fabricated or manipulated fingerprint or other forensic evidence or testified falsely in relation to such evidence.

Mr. Roth obtained a conviction1 against New York State Police Officer Robert Lishansky for fabricating fingerprint evidence in the cases People v Longtin, People v Hallock, People v Lucas and People v Muniz.2

The petitioner’s FOIL request was for the following specific records and documents:

"1. Accusatory instruments;

"2. Arrest/investigatory reports;

"3. Statements of complainants and witnesses, including but not limited to Mr. David Harding;

"4. Statements of Mr. Robert Lishansky. Reference is made to Exhibit B, Page 1, which states that members of the State Police Inspection team met with prosecutors within the Troop C area, and that 'based on a review of the physical evidence and on statements made by Lishansky to the Special Prosecutor and the police, the State Police inspection team has concluded’;

"5. Reports, memoranda, statements, correspondence, or documents regarding the above referenced statements by Mr. Robert Lishansky;

"6. Reports, memoranda, statements, correspondence, or documents regarding the conclusions reached by the State Police Inspection team as to the falsity of the Latent Print Examination form General 33, attached hereto as Exhibit 'C\

"7. Reports, memoranda, statements, correspondence or documents regarding the conclusions reached by the State Police Inspection team as to the falsity of the fingerprints of Lee Longtin and Daryl Hallock set forth in Exhibit 'C\

"8. Communications log entries of any kind regarding the [296]*296falsification of fingerprint evidence by Mr. Robert Lishansky.” (Petitioner’s exhibit A, schedule A.)

The petitioner’s attorney both at motion term and by letter dated August 5, 1994 clarified the FOIL request by confirming, "what we intend to request is simply all the information within the categories set forth in schedule A of the demand as related only to the fingerprints of Lee Longtin and Daryl Hallock * * * our intention is to make no demand for information other than that which relates to the two fingerprints” (respondent’s exhibit B).

Mr. Roth refuses the request to produce the documents for the following reasons.

As to item 1, he has no accusatory instruments in his files relating to Longtin, Hallock or Muniz; the accusatory instrument he does have relates to Robert Lishansky and is a public record on file in the Tompkins County Clerk’s Office.

Information sought under items 2, 3, 5, 6 and 7 would interfere with law enforcement investigations or judicial proceedings because the investigation with regard to Lishansky and others is continuing. The disclosure of the requested records would identify confidential information, and may reveal criminal investigative techniques. Mr. Roth contends that the records set forth the manner in which fabricated fingerprints are located and identified. He believes that disclosure of this highly specialized technique may well aid others to cover up such acts in the future.

On item 4, besides the reason of an ongoing investigation, Mr. Roth argues that certain statements made by Lishansky were made during confidential hearings conducted pursuant to section 6 of the Executive Law and section 73 of the Civil Rights Law, and would therefore be exempt pursuant to Public Officers Law § 87 (2) (a). That section protects from disclosure records that "are specifically exempted from disclosure by state or federal statute”. (Public Officers Law § 87 [2] [a].)

Lastly, on the records requested in item 8, Mr. Roth contends no such documents exist and he has no such documents in his files.

DISCUSSION

The legislative intent in enacting FOIL was to make available to the public documents generated by and in the possession of government unless a compelling reason requires their [297]*297confidentiality. (Public Officers Law § 84; Matter of Gannett News Serv. v State of N. Y. Off. of Alcoholism & Drug Abuse, 99 Misc 2d 235.)

In determining whether the documents sought come within one of the statutory exemptions, "the FOIL exemptions are to be narrowly construed, and the burden to establish the applicability of an exemption is on the agency seeking to prevent disclosure” (Matter of Spencer v New York State Police, 187 AD2d 919, 920 [3d Dept 1992]).

The objection to item 1 (the availability of the record in the Tompkins County Clerk’s Office) is baseless. FOIL does not require a showing of need for the requested record. (See, Matter of Farbman & Sons v New York City Health & Hosps. Corp., 62 NY2d 75, 80.) The fact that a document subject to FOIL is available elsewhere does not free the agency from its duty under FOIL to disclose the document.

Mr. Roth’s principal argument to the remaining disclosure is that the records relate to a continuing criminal investigation, and the records would reveal nonroutine criminal investigative techniques. He has not met his burden to claim the exemption.

Fingerprint tests have been held to be an example of routine investigative techniques. (Matter of Moore v Santucci, 151 AD2d 677, 679.) The methods of discovering fabricated fingerprints have not been shown to be unique, or to deserve an exemption not afforded fingerprint tests.

The science of detecting phony fingerprint evidence may have been raised to a new level in Mr. Roth’s special investigation, but the process of locating and identifying fabricated fingerprints appears to be a routine methodology. This methodology was the subject of testimony in open court by New York State Police Senior Investigator Vincent Rosetti (petitioner’s exhibit A), and the same information was further conveyed to the Tompkins County District Attorney (petitioner’s exhibit B).

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Related

Fink v. Lefkowitz
393 N.E.2d 463 (New York Court of Appeals, 1979)
M. Farbman & Sons, Inc. v. New York City Health
464 N.E.2d 437 (New York Court of Appeals, 1984)
Moore v. Santucci
151 A.D.2d 677 (Appellate Division of the Supreme Court of New York, 1989)
Cornell University v. City of New York Police Department
153 A.D.2d 515 (Appellate Division of the Supreme Court of New York, 1989)
Mahoney v. Staffa
184 A.D.2d 886 (Appellate Division of the Supreme Court of New York, 1992)
Spencer v. New York State Police
187 A.D.2d 919 (Appellate Division of the Supreme Court of New York, 1992)
Gannett News Service, Inc. v. State
99 Misc. 2d 235 (New York Supreme Court, 1979)

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Bluebook (online)
163 Misc. 2d 293, 620 N.Y.S.2d 700, 1994 N.Y. Misc. LEXIS 559, Counsel Stack Legal Research, https://law.counselstack.com/opinion/muniz-v-roth-nysupct-1994.