People v. Ceda

2024 NY Slip Op 50272(U)
CourtThe Criminal Court of the City of New York, Bronx
DecidedMarch 14, 2024
StatusUnpublished
Cited by1 cases

This text of 2024 NY Slip Op 50272(U) (People v. Ceda) is published on Counsel Stack Legal Research, covering The Criminal Court of the City of New York, Bronx primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Ceda, 2024 NY Slip Op 50272(U) (N.Y. Super. Ct. 2024).

Opinion

People v Ceda (2024 NY Slip Op 50272(U)) [*1]
People v Ceda
2024 NY Slip Op 50272(U)
Decided on March 14, 2024
Criminal Court Of The City Of New York, Bronx County
González-Taylor, 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This opinion is uncorrected and will not be published in the printed Official Reports.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 March 14, 2024
Criminal Court of the City of New York, Bronx County


The People of the State of New York,

against

Jose Ceda, Defendant.




Docket No. CR-014763-23BX

For the People:
Darcel D. Clark, District Attorney, Bronx County
by: ADA Casey M. McIntyre

For the Defendant:
The Legal Aid Society
by: Katherine Kuhl, Esq.
Yadhira González-Taylor, J.

By motion dated, January 8, 2024, defendant, Jose Ceda, moves for an order deeming the People's Certificate of Compliance ("CoC"), filed October 5, 2023, invalid due to the prosecution's failure to disclose discoverable materials pursuant to CPL §§ 245.20 (1) and 245.50 (1) and for a ruling that the People's supplemental CoCs, filed October 6, 2023, and November 13, 2023, support a finding that the initial CoC should be invalidated; and further for dismissal of the accusatory instrument pursuant to CPL §§ 170.30 (1) (e) and 30.30.

Further, defendant contemporaneously moved for omnibus relief, requesting an order suppressing identification evidence pursuant to CPL §§ 710.20 (6), (4) and 710.60 or, alternatively granting a Wade/Dunaway hearing; granting a pre-trial voluntariness hearing concerning statements sought to be used only on cross-examination of defendant pursuant to CPL §§ 60.45, 710.20 (3) and 710.40 (3); granting a pre-trial voluntariness hearing concerning statements made to civilians pursuant to CPL §§ 60.45 (2), 710.20 (3); People v Grillo, 176 AD2d 346 [2d Dept 1991] and 710.40 (3); precluding the admission of evidence pursuant to CPL § 710.30; directing the prosecution to comply with defendant's request for a Bill of Particulars pursuant to CPL §§ 200.95 (2) and (5); directing the People to comply with their disclosure obligations pursuant to CPL §§ 245.55 (2) and (3) and to preserve and disclose complete records of the investigation and prosecution of the case, including 911 calls and police recordings; requiring the prosecution to comply with Brady/Vilardi requests; directing the prosecution to file an additional CoC pursuant to CPL § 245.35 (3) certifying that reasonable inquiries were made pursuant to CPL § 245.20 (1) (k); granting Sandoval hearing pursuant to CPL §§ 245.10 (1) (b) and 245.20 (3); and allowing defendant to reserve the right to file additional motions as necessary.

Upon review and consideration of the submissions, court file and relevant legal authority, [*2]the Court finds that the People's CoC dated, October 5, 2023, was VALID; and:

The People's supplemental CoCs filed October 6, 2023, and November 13, 2023, do not support a finding that their CoC should be invalidated; and
The prosecution pursuant to CPL §§ 170.30 (1) (e) and 30.30 was TIMELY; and
Defendant's motion to dismiss the accusatory instrument is DENIED; and
Defendant's motion for Wade/Dunaway/Huntley pre-trial hearings is GRANTED; and
Defendant's request for an order suppressing evidence pursuant to CPL §§ 710.20 (6), (4) and 710.60 is DENIED; and
Defendant's application seeking the right to make further motions is GRANTED to the extent provided by CPL § 255.20 (3); and
Defendant's request for a Sandoval hearing is respectfully REFERED to the trial court; and
Defendant's right to move for preclusion for discovery pursuant to CPL § 245.80 is RESERVED for consideration by the trial court; and
The People are DIRECTED to comply with their continuing discovery obligations pursuant to CPL §§ 200.95 and 245, including Brady/Vilardi disclosures.


RELEVANT PROCEDURAL BACKGROUND

On July 6, 2023, defendant, Jose Ceda, was arrested and charged with violating Criminal Procedure Law ("CPL") §§ 121.11 (a) (criminal obstruction of breathing or blood circulation), 120.00 (1) (assault in the third degree), 145.00 (1) (criminal mischief in the fourth degree), all misdemeanors, and 240.26 (1) (harassment in the second degree), a violation. On July 7, 2023, defendant was arraigned and released on his own recognizance.

The People filed their initial CoC and Statement of Readiness ("SoR") on October 5, 2023, which was supplemented by CoC and SoR dated October 6, 2023, with the disclosure of body worn camera ("BWC") video for Police Officer Melvin Rodriguez ("PO Rodriguez"). At a discovery conference held on November 1, 2023, before Honorable E. Deronn Bowen, defense counsel reported to the court that she and the assigned had conferred and that she was under advisement that the People were working with the officers and discovery liaisons to procure outstanding discovery, and the court ordered the prosecution to disclose discovery related to the complaining witness's contacts with law enforcement by November 15, 2023, and directed the two weeks to be excluded from chargeable time.

On November 13, 2023, the People served a third CoC and SoR with "4 folders of DD5s, including Cases Numbered 2023-1843, 2023-965 and 2023-3002," the basis for which was stated as "despite the exercise of diligent, good faith efforts, this material was previously unavailable to the People, but now has been obtained by the People." At the discovery conference held on December 12, 2023, this Court noted that the assigned ADA reported that she had reached out to her discovery liaison for BWC, activity logs and DD5 reports for two officers who conducted a domestic home visit on the date of the alleged incident which precipitated defendant's arrest, to no avail, and the instant motion schedule was set. Defendant's motion was filed on January 8, 2024, the People filed their opposition on February 9, 2024, to which defense counsel replied on February 22, 2024.



DISCUSSION


I. Applicable Standard for CoC Challenge

To oppose a motion to dismiss which claims that the prosecution's CoC is illusory due to [*3]the prosecution's alleged failure to comply with CPL § 245.20, the People must demonstrate that they met their burden by detailing their efforts to obtain discoverable information (see People v Hernandez, 81 Misc 3d 1201[A], 2023 NY Slip Op 51201[U], *6 [Crim Ct, Bronx County 2023] citing People v Adrovic, 69 Misc 3d 563, 572 [Crim Ct, Kings County 2020]; CPL § 245.50 [3]).

If the record does not establish that the People have detailed their efforts to discharge their obligation such that a court cannot determine their due diligence, the CoC must be deemed invalid (see Hernandez, 2023 NY Slip Op 51201[U], *7 citing People v Perez, 75 Misc 3d 1205[A], 2022 NY Slip Op 50387[U], *3 [Crim Ct, Bronx County 2022]; People v Georgiopoulous

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Related

People v. Ceda
2024 NY Slip Op 50272(U) (Bronx Criminal Court, 2024)

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2024 NY Slip Op 50272(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-ceda-nycrimctbronx-2024.