People v. Arneo

2024 NY Slip Op 50522(U)
CourtWebster Justice of the Peace Court
DecidedMay 3, 2024
StatusUnpublished

This text of 2024 NY Slip Op 50522(U) (People v. Arneo) is published on Counsel Stack Legal Research, covering Webster Justice of the Peace Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Arneo, 2024 NY Slip Op 50522(U) (N.Y. Super. Ct. 2024).

Opinion

People v Arneo (2024 NY Slip Op 50522(U)) [*1]
People v Arneo
2024 NY Slip Op 50522(U)
Decided on May 3, 2024
Justice Court Of The Town Of Webster, Monroe County
DiSalvo, J.
Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431.
This opinion is uncorrected and will not be published in the printed Official Reports.


Decided on May 3, 2024
Justice Court of the Town of Webster, Monroe County


The People of the State of New York

against

Brielle Arneo, Defendant.




Case No. 23060001

Sandra Doorley, District Attorney, Monroe County (Elizabeth D. Buckley and Kirby W. Leggett [awaiting admission] of Counsel), for plaintiff.

Jeremiah S. King, Rochester, for defendant.
Thomas J. DiSalvo, J.
History and Facts of the Case

The defendant was charged with driving while impaired by drugs, VTL § 1192 (4), failure to use designated lane, VTL 1128 (c) and criminal possession of a controlled substance in the seventh degree, P.L. § 220.03. Said offenses were alleged to have occurred on May 27, 2023 at approximately 5:05 P.M. on Lake Road in the Town of Webster. The defendant was charged by uniform traffic informations on the first two charges and by an information as to the latter charge. Webster Police were called to the scene to investigate a one car motor vehicle accident. Upon arrival at the scene the police found the defendant's vehicle facing eastbound on the grass on the south side of the road. After a series of questions by Officer Ceneviva directed at the defendant, the defendant was asked to perform certain roadside field sobriety tests, including the horizontal gaze nystagnus, the walk and turn test and the one-leg stand test. The defendant was asked and consented to take the roadside breath test. Upon completion of said tests the defendant was arrested at about 5:40 P.M. and transported to the Webster Police Department. After arriving at the police department she was read the Miranda warnings. Those warnings were read to her at 6:27 P.M. A drug recognition expert, Greece P Police Officer Garrett C. Fries, was called to perform an evaluation of the defendant. That evaluation began at 7:17 P.M. and concluded at 8:13 P.M. Subsequently she was asked to take a second chemical test of her breath, presumably at the request of the DRE, at approximately 8:15 P.M. She was read the commissioner's warnings relative to a refusal to take such a test. However, she reportedly refused to take that test three times, namely at 8:15 P.M., 8:21 P.M. and 8:30 P.M., saying "No" in response to each reqest. Those facts are gleaned from a "Report of Refusal to Submit to Chemical Test". However, also filed with the court was a "Supporting Deposition Breath Test Administration" sworn to by Webster Police Officer Store, attesting to the fact that a chemical test was first taken by the defendant at 7:13 P.M., which resulted in a chemical analysis of "0.00". In fact a certified copy of [*2]the said chemical test filed with the court confirmed said finding.[FN1] She was eventually issued an appearance ticket returnable on June 7, 2023, at which time she was arraigned and released on her own recognizance.

On December 20, 2023 defense counsel filed Omnibus Motions with the court, wherein it was requested, among other things, that statements made by the defendant be suppressed or in the alternative a Huntley hearing and suppression of the Drug Recognition Expert [DRE] examination. The People filed a Cross Motion and Responding Affirmation with the court on January 24, 2024. The court granted the requests for said hearing, which was conducted on April 12, 2024. At that hearing the People presented one witness, i.e. Webster Police Officer John Ceneviva. Prior to the start of the hearings, the attorneys stipulated into evidence the officer's Miranda warning card, the body worn camera footage and the drug recognition expert's report. It was agreed that the court would view the body worn camera footage at a later time.[FN2] The officer testified as to the facts and circumstances previously set out herein. He further testified to the unsatisfactory performance of the defendant on the roadside field sobriety tests. The accuracy of the officer's testimony was confirmed by this court upon viewing the body worn camera footage. He testified as to the issuance of both the Miranda and Commissioner's warnings. At the end of the Miranda warnings, the defendant was asked, "Do you agree to talk with me now?" In response the defendant stated "I don't feel comfortable without a lawyer present." It is un-controverted that the DRE officer did not read the defendant Miranda warnings prior to his questioning and examination. In fact the DRE Recognition Evaluation states in paragraph "10" that "Miranda was previously read to the subject at 18:27 hours [i.e. 6:27 P.M.] by Officer Ceneviva".



Issues Presented.

Should the statements made by the defendant to the arresting officer subsequent to his reading the Miranda rights to the defendant be suppressed?

Should the statements made by the defendant to the DRE officer be suppressed?

Should the results of the Drug Recognition Evaluation be suppressed?


Legal Analysis.

Statements to Arresting Officer. Defense counsel is requesting that all statements made by the defendant subsequent to her arrest at 5:40 P.M. be suppressed. The issue then becomes [*3]whether the defendant agreed to waive her Miranda rights and speak to the arresting officer by her statement that "I don't feel comfortable without a lawyer present." The standard established by the Court of Appeals is that a waiver of one's right to counsel during questioning by the police must be unequivocal.[FN3]

"When a defendant in custody unequivocally requests the assistance of counsel, any purported waiver of that right obtained in the absence of counsel is ineffective ... However, when the defendant's request is not unequivocal, the right to counsel does not attach .... Whether a particular request is or is not unequivocal is a mixed question of law and fact that must be determined with reference to the circumstances surrounding the request including the defendant's demeanor, manner of expression and the particular words found to have been used by the defendant [internal citations omitted]" (People v. Glover, 87 NY2d 838,839, 637 N.Y.S.2d 683 [1995]

This then raises the question as to whether the statement of the defendant was an unequivocal request for an attorney. A statement can be an unequivocal request for an attorney based on the circumstances, the defendant's demeanor, manner of expression and the particular words found to have been used by the defendant. In a previous case the Court of Appeals held that a statement by the defendant, after he had been advised of his rights, that "I might need a lawyer", was sufficient to establish that the defendant had invoked his right to counsel. (See People v.Esposito, 68 NY2d 961, 510, N.Y.S. 542 [1986]).

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Cite This Page — Counsel Stack

Bluebook (online)
2024 NY Slip Op 50522(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-arneo-nywebsterjustct-2024.