People v. Quintana

2025 NY Slip Op 50596(U)
CourtThe Criminal Court of the City of New York, Bronx
DecidedApril 17, 2025
DocketDocket No. CR-012868-24BX
StatusUnpublished

This text of 2025 NY Slip Op 50596(U) (People v. Quintana) 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. Quintana, 2025 NY Slip Op 50596(U) (N.Y. Super. Ct. 2025).

Opinion

People v Quintana (2025 NY Slip Op 50596(U)) [*1]
People v Quintana
2025 NY Slip Op 50596(U)
Decided on April 17, 2025
Criminal Court Of The City Of New York, Bronx County
Lewis, 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This opinion is uncorrected and will not be published in the printed Official Reports.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 April 17, 2025
Criminal Court of the City of New York, Bronx County


The People of the State of New York,

against

Nelson Quintana, Defendant.




Docket No. CR-012868-24BX

Defense Counsel

Shanisha Forbes

The Bronx Defenders

360 East 161st Street

Bronx, NY 10451

sforbes@bronxdefenders.org

Bronx District Attorney's Office

Assistant District Attorney Jason Isaacs

198 East 161st Street

Bronx, NY 10451

IsaacsJ@Bronxda.nyc.gov
Daniel M. Lewis, J.

Defendant Nelson Quintana is charged by information with Reckless Endangerment in the Second Degree (Penal Law [PL] § 120.20), a class A misdemeanor; Operating a Motor Vehicle While Under the Influence of Alcohol or Drugs (Vehicle and Traffic Law [VTL] § 1192 [3]), Reckless Driving (VTL § 1212), unclassified misdemeanors, and one count of Driving While Ability Impaired (VTL § 1192[1]), a traffic infraction.

Defendant moves to dismiss the information pursuant to CPL §§ 30.30(1) and 170.30(1)[e], arguing the People's failure to properly certify compliance with CPL Article 245's discovery mandates rendered their August 30, 2024, Certificate of Compliance (COC) invalid and Statement of Readiness (SOR) illusory.

As explained below, Defendant's motion to invalidate the People's COC, find the SOR [*2]illusory, and dismiss the case pursuant to CPL § 170.30(1)(e) and CPL § 30.30(1) is GRANTED.



Pertinent Procedural History

Defendant stands charged with VTL § 1192(3) and other related charges. Defendant was arraigned on June 2, 2024. The case was adjourned to July 18, 2024, for conversion and the COC. On July 18, 2024, the complaint was deemed an information and Defendant was arraigned on the information. The matter was adjourned to August 13, 2024, for the People's COC and screening and assessment results.

On August 13, 2024, the People had not yet filed a COC and SOR. The matter was adjourned to September 17, 2024, for the People's COC and screening and assessment results. On August 30, 2024, off-calendar, the People filed their COC and SOR.

On September 9, 2024, the People filed their first supplemental COC ("SCOC") detailing the disclosure of updated medical records for PO Dembele, prisoner movement slip, and WINQ.

On September 17, 2024, the Court and defense counsel acknowledged the People's off calendar filing. Defense counsel requested additional time to review discovery, and the case was adjourned to October 8, 2024, for a discovery conference.

On October 8, 2024, the defendant's appearance was excused. The People indicated that they requested outstanding materials from NYPD and were awaiting their response. The matter was adjourned to November 6, 2024, for discovery compliance.

On October 7, the People filed a second SCOC signaling the disclosure of updated calibration, gas chromatography, and simulator solutions reports.

On November 6, 2024, a discovery conference was held. The People indicated that they secured memobooks and would provide the full scratch complaint report to defense once they obtained it. They also represented that they would continue to follow up with NYPD regarding outstanding materials. The matter was adjourned to November 22, 2024, for a discovery update. On November 22, 2024, with unresolved discovery issues remaining the Court set a motion schedule and adjourned the matter to February 13, 2025, for decision.

On November 8, 2024, the People filed their third SCOC memorializing their disclosure of memobooks for Police Officers Mendoza and Dipaoli and the entire Scratch 61.

On November 19, 2024, the People filed a fourth SCOC confirming the disclosure of body worn camera footage for Inspector John Potkay.

On February 13, 2025, the People answered ready. The matter was adjourned to March 25, 2025, for the Court's decision. Thereafter the case was administratively adjourned to April 4, 2024.



Discussion

The Court finds that the People's efforts prior to the filing of their COC did not evince the due diligence, good faith and reasonable inquiry necessary for COC validity.

"[T]he key question in determining if a proper COC has been filed is whether the prosecution has 'exercise[d] due diligence and ma[de] reasonable inquiries to ascertain the existence of material and information subject to discovery'" (People v Bay, 41 NY3d 200, 212 [2023], quoting CPL § 245.20[2]). Although "[t]here is no rule of 'strict liability' . . . the plain terms of the statute make clear that while good faith is required, it is not sufficient standing alone and cannot cure a lack of due diligence" (id. at 212).

While a belated filing will not necessarily invalidate a COC or denote a lack of due diligence, a belated filing also "cannot compensate for a failure to exercise diligence before the initial COC is filed" (People v Bay, 41 NY3d at 212). It is the People's burden to establish that they exercised due diligence and made reasonable inquiries prior to filing their original COC (id. at 213). If the prosecution fails to satisfy such burden, the COC should be deemed improper and the accompanying statement of readiness invalid (id at 213).

In this case, the prosecution belatedly disclosed several items subject to the automatic discovery provisions of CPL § 245.20, namely, memobooks, body worn camera footage, gas chromatography reports, calibration reports and simulator solution reports, the existence of which, given the nature of the offenses charged should have been apparent to the prosecution at the commencement of this matter.[FN1] To be sure, belated disclosure is not the death knell of a COC. As is well settled by now, a sufficient showing of good faith, due diligence, and reasonable inquiry prior to the People filing their COC will normally support the COC's validity despite belated disclosure. However, the People bear the burden to set forth those efforts when their COC is challenged.

Here, the People's recitation is replete only with efforts to obtain these items after defense counsel notified them that they were missing and is utterly bereft of their efforts to obtain these items prior to the filing of their COC. As stated above, a belated filing will not necessarily invalidate a COC, but it also "cannot compensate for a failure to exercise diligence before the initial COC is filed" (People v Bay, 41 NY3d at 212).

Based on the record presently before it, the Court cannot ascertain what efforts were made by the People to acquire these routine and critical pieces of discovery prior to the COC filing date. Nor can the Court extrapolate due diligence from factual details that were not provided. Absent any record to the contrary, the Court must conclude that the People failed to evince the requisite reasonable inquiries, due diligence, and good faith prior to filing their COC.

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Bluebook (online)
2025 NY Slip Op 50596(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-quintana-nycrimctbronx-2025.