People v. Lebron

2024 NY Slip Op 50593(U)
CourtThe Criminal Court of the City of New York, Bronx
DecidedMay 19, 2024
StatusUnpublished

This text of 2024 NY Slip Op 50593(U) (People v. Lebron) 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. Lebron, 2024 NY Slip Op 50593(U) (N.Y. Super. Ct. 2024).

Opinion

People v Lebron (2024 NY Slip Op 50593(U)) [*1]
People v Lebron
2024 NY Slip Op 50593(U)
Decided on May 19, 2024
Criminal Court Of The City Of New York, Bronx County
Gonzalez-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This opinion is uncorrected and will not be published in the printed Official Reports.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 May 19, 2024
Criminal Court of the City of New York, Bronx County


The People of the State of New York,

against

Lieliz Lebron, Defendant.




Docket No. CR-022605-23BX

For the People:

Darcel D. Clark, District Attorney, Bronx County

(by: ADA Jennifer Rentrope)

For the Defendant:

The Bronx Defenders

(by: Lawrence Pierce, Esq.)
Yadhira González-Taylor, J.

By omnibus motion dated March 21, 2024, defendant Lieliz Lebron moves this Court to dismiss the accusatory instrument pursuant to Criminal Procedure Law ("CPL") § 30.30 (1) (b), inter alia, on the grounds that the prosecution has failed to comply with its § 245.20 (1) automatic disclosures and, thus, the People's Certificate of Compliance ("CoC") should be deemed invalid, and the period of their non-compliance charged against them. Alternatively, defendant seeks an order suppressing statement and identification evidence, or hearings pursuant to Huntley/Dunaway and Wade/Crews/Rodriguez, respectively, and a hearing on the underlying facts pursuant to People v Allard, 28 NY3d 41 [2016] if the prosecution opposes the motion. On April 18, 2024, the prosecution opposed the motion except that part requesting a Huntley hearing. On April 25, 2024, defendant filed his reply. Upon review and consideration of the submissions, court file and relevant legal authority, the Court:

DENIES defendant's motion to dismiss; and
DEEMS the People's CoC, dated January 12, 2024, VALID; and
DIRECTS the People to disclose records of prior convictions for their complainant, Abagail Davis, NYSID # 9008554M, including dockets CR-011852-22BX and CRH-026328-11BX, within seven (7) days of this Decision and Order; and
DIRECTS the People to file and serve a supplemental CoC certifying compliance with their disclosure obligations concerning the complaining witness pursuant to this Order contemporaneously with their disclosure; and
DENIES defendant's request for an order suppressing evidence but GRANTS defendant's request for pre-trial Huntley/Dunaway and Wade/Crews/Rodriguez hearings; and
FINDS that there are no unresolved issues that warrant a hearing on the underlying facts pursuant to Allard at 41.

This constitutes the opinion, decision, and order of the Court.

RELEVANT PROCEDURAL BACKGROUND

On October 14, 2023, defendant Lieliz Lebron was arrested and charged with violating Penal Law ("PL") §§ 121.11 (criminal obstruction of breathing or blood circulation) and 120.00 (1) (assault in the third degree), both misdemeanors, and 240.26 (harassment in the second degree), a violation. Defendant was arraigned on October 15, 2023, and released on her own recognizance.

At the discovery conference held on February 22, 2024, defense counsel advised this Court that the parties had not conferred concerning disputed discovery items detailed in his email to the assigned ADA dated January 23, 2024, which sought information concerning outstanding body-worn camera ("BWC") footage, memo book entries and Giglio material for Police Officer ("PO") Olan, prior conviction information for the complaining witness, and a surname for another prosecution witness. Accordingly, the instant motion schedule was set.



DISCUSSION

I. Applicable Legal Standards

The CoC Challenge

To oppose a motion to dismiss claiming that the prosecution's CoC is illusory due to 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]).

In People v Bay, the Court of Appeals addressed the issue of how trial courts can evaluate prosecutorial due diligence (see Bay, — NE3d &mdash, 2023 NY Slip Op 06407 [2023]). The Bay Court found that the "key question in determining if a proper certificate of compliance has been filed is whether the prosecution has exercised due diligence and made reasonable inquiries to determine the existence of material and information subject to discovery," a case-specific inquiry of the record at bar (see Bay, 2023 NY Slip Op 06407, *2 [emphasis added]; CPL §§ 245.20 [1], 245.50 [1]).



The CPL § 30.30 Challenge

In a motion to dismiss misdemeanor charges pursuant to CPL § 30.30, a defendant has the initial burden to demonstrate that the prosecution failed to declare readiness for trial within ninety days (see CPL § 30.30 [1] [b]); see People v Luperon, 85 NY2d 71, 77-78 [1995]). Generally, a criminal action is commenced by the filing of an accusatory instrument against a defendant, and it is settled law that the date on which the action is commenced is excluded from the CPL § 30.30 computation (see CPL § 1.20 [17]; People v Stiles, 7 NY2d 765, 767 [1987]).

Additionally, the People must now satisfy their statutory obligation pursuant to CPL § 245.50 (3), which provides that "the prosecution shall not be deemed ready for trial for purposes of section 30.30 of this chapter until it has filed a proper certificate pursuant to subdivision one of this section" (see People v Kendzia, 64 NY2d 331, 337 [1985]). Consequently, courts must examine the prosecution's due diligence to determine the validity of the CoC and, importantly, [*2]whether the accusatory instrument should be dismissed as a consequence of any chargeable period of non-compliance which renders the prosecution untimely (see Bay, 2023 NY Slip Op 06407, *2).



II. The Parties' Arguments

Defendant argues that the prosecution's CoC should be invalidated because of the People's failure to disclose memo book entries which correlate to PO Olan's response to the subject incident (memorandum of law of defendant's counsel at § A). Moreover, counsel posits that the prosecution is obliged to disclose Giglio evidence for PO Olan, one of only two police officers who responded to the scene, because he played an integral role in defendant's investigation and arrest (Id.).

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Related

People v. Luperon
647 N.E.2d 1243 (New York Court of Appeals, 1995)
The People v. Dru Allard
63 N.E.3d 1140 (New York Court of Appeals, 2016)
People v. Kendzia
476 N.E.2d 287 (New York Court of Appeals, 1985)

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2024 NY Slip Op 50593(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-lebron-nycrimctbronx-2024.