People v. Kohler

2024 NY Slip Op 51878(U), 87 Misc. 3d 1213(A)
CourtNew York Justice Court
DecidedJanuary 16, 2024
DocketDocket No. 22110234
StatusUnpublished
Cited by1 cases

This text of 2024 NY Slip Op 51878(U) (People v. Kohler) is published on Counsel Stack Legal Research, covering New York Justice Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Kohler, 2024 NY Slip Op 51878(U), 87 Misc. 3d 1213(A) (N.Y. Super. Ct. 2024).

Opinion

People v Kohler (2024 NY Slip Op 51878(U)) [*1]

People v Kohler
2024 NY Slip Op 51878(U) [87 Misc 3d 1213(A)]
Decided on January 16, 2024
Justice Court Of The Town Of Clarence, Erie County
Hickey, 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This opinion is uncorrected and will not be published in the printed Official Reports.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 January 16, 2024
Justice Court of the Town of Clarence, Erie County


The People of the State of New York,

against

David Kohler, Defendant.




Docket No. 22110234

John Flynn, Esq.
Erie County District Attorney
BY: Sandra K. Cassidy, Esq.
William Szcepanski, Esq.
Assistant District Attorneys
Attorneys for the People

Peter J. Todoro, Jr., Esq.
Attorney for the Defendant Jonathan S. Hickey, J.

The defendant is charged in three separate incidents, all of which are made part of the present motion. By way of introduction each of the dates and specific charges are set forth below:

April 2, 2022:

• Harassment in the Second Degree, Penal Law § 240.26 [FN1]

• Endangering the Welfare of a Child, Penal Law § 260.10 (5 counts)

• Assault in the Third Degree, Penal Law § 120.00(2)

• Reckless Endangerment in the Second Degree, Penal Law § 120.20

September 6, 2022:

• Harassment in the Second Degree, Penal Law § 240.26(3)[FN2]

• Criminal Contempt in the Second Degree, Penal Law § 215.50(3)

December 11, 2022:

• Harassment in the Second Degree, Penal Law § 240.26(3)

• Criminal Contempt in the Second Degree, Penal Law § 215.50(3)

Procedural Posture:

The defendant pleaded not guilty to all charges and on April 17, 2023 filed a Notice of Motion to Dismiss pursuant to Criminal Procedure Law §§ 170.30(1), 170.35(1), and 100.40(1). The People opposed the motion and submitted the Affirmation in Opposition to Defense of William E. Szczepanski, Esq. sworn to on September 14, 2023. During a September 21, 2023 preliminary conference the parties agreed to submit all motion arguments on the papers. The ex-spouse of the defendant is the complainant and their minor children will be addressed as M. and C. or as the "children" due to their ages.

Conclusions of Law:

Facial Insufficiency:

CPL § 100.15 Information, misdemeanor complaint and felony complaint; form and content provides that:
1. An information, a misdemeanor complaint and a felony complaint must each specify the name of the court with which it is filed and the title of the action, and must be subscribed and verified by a person known as the "complainant." The complainant may be any person having knowledge, whether personal or upon information and belief, of the commission of the offense or offenses charged. Each instrument must contain an accusatory part and a factual part. The complainant's verification of the instrument is deemed to apply only to the factual part thereof and not to the accusatory part.
2. The accusatory part of each such instrument must designate the offense or offenses charged. As in the case of an indictment, and subject to the rules of joinder applicable to indictments, two or more offenses may be charged in separate counts. Also as in the case of an indictment, such instrument may charge two or more defendants provided that all such defendants are jointly charged with every offense alleged therein.
3. The factual part of such instrument must contain a statement of the complainant alleging facts of an evidentiary character supporting or tending to support the charges. Where more than one offense is charged, the factual part should consist of a single factual account applicable to all the counts of the accusatory part. The factual allegations may be based either upon personal knowledge of the complainant or upon information and belief. Nothing contained in this section, however, limits or affects the requirement, prescribed in subdivision one of section 100.40, that in order for an information or a [*2]count thereof to be sufficient on its face, every element of the offense charged and the defendant's commission thereof must be supported by non-hearsay allegations of such information and/or any supporting depositions. (Emphasis added).
CPL § 100.40 Local criminal court and youth part of the superior court accusatory instruments; sufficiency on face, provides in relevant part that:
1. An information, or a count thereof, is sufficient on its face when:
(a) It substantially conforms to the requirements prescribed in section 100.15; and
(b) The allegations of the factual part of the information, together with those of any supporting depositions which may accompany it, provide reasonable cause to believe that the defendant committed the offense charged in the accusatory part of the information; and
(c) Non-hearsay allegations of the factual part of the information and/or of any supporting depositions establish, if true, every element of the offense charged and the defendant's commission thereof. (Emphasis added).

"A valid and sufficient accusatory instrument is a nonwaivable, jurisdictional prerequisite to a criminal prosecution. Every information must contain an accusatory part and a factual part (CPL § 100.15 [1]). The allegations of the factual part of the information, together with those of any supporting deposition which may accompany it, must provide the court with reasonable cause to believe that the defendant committed the offense charged in the accusatory part of the information (CPL § 100.40 [1] [b]). Moreover, non hearsay allegations of the factual part of the information and/or any supporting depositions must establish, if true, every element of the offense charged and the defendant's commission thereof. This standard does not require proof beyond a reasonable doubt or evidence sufficient to warrant a conviction, but merely information which would lead a reasonable person who possesses the same expertise as the officer to conclude that a crime is being or was committed" (People v Russo, 24 Misc 3d 655, 656 [Nassau Dist Ct, First District, 2009]) (internal citations omitted).

"Reasonable cause to believe that a person has committed an offense" exists when evidence or information which appears reliable discloses facts or circumstances which are collectively of such weight and persuasiveness as to convince a person of ordinary intelligence, judgment and experience that it is reasonably likely that such offense was committed and that such person committed it (see CPL § 70.10(2)).

People v Casey (95 NY2d 354 [2000]) sets forth the guidelines for analyzing the facial sufficiency of an accusatory including the principle that so long as the factual allegations of an information give an accused notice sufficient to prepare a defense and are adequately detailed to prevent a defendant from being tried twice for the same offense, they should be given a fair and not overly restrictive or technical reading.

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Cite This Page — Counsel Stack

Bluebook (online)
2024 NY Slip Op 51878(U), 87 Misc. 3d 1213(A), Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-kohler-nyjustct-2024.