People v. Reddick

50 Misc. 3d 622, 23 N.Y.S.3d 807
CourtCriminal Court of the City of New York
DecidedNovember 9, 2015
StatusPublished

This text of 50 Misc. 3d 622 (People v. Reddick) is published on Counsel Stack Legal Research, covering Criminal Court of the City of New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Reddick, 50 Misc. 3d 622, 23 N.Y.S.3d 807 (N.Y. Super. Ct. 2015).

Opinion

OPINION OF THE COURT

Heidi C. Cesare, J.

Defendant is charged in an information with obstructing governmental administration in the second degree (Penal Law § 195.05), resisting arrest (Penal Law § 205.30), unlawful vending in a city park (56 RCNY 1-05 [b] [1]) and disorderly conduct (Penal Law § 240.20). In his omnibus motion defendant moves (1) to dismiss all counts in the information as facially insufficient, (2) to preclude unnoticed statement and identification testimony, (3) to preclude prior bad acts evidence, (4) to compel a bill of particulars and discovery, and (5) for the right to make further motions as necessary. In their response, the People also move for reciprocal discovery. For the reasons set forth below, defendant’s motion to dismiss is denied and the remaining motions of both parties are granted.1

I. Allegations

The factual allegations of the accusatory instrument provide that on or about May 27, 2015 at about 2:00 p.m., in front of 80 South Street in the County and State of New York:

“[Deponent is] informed by [informant patrolman] that he observed the defendant, on Pier 15 in front of 80 South Street, in the County and State of New York, approaching numerous pedestrians and offering to sell them tour tickets. [Deponent is] further informed that [informant patrolman] observed one individual give the defendant USC in exchange for tickets. [Deponent is] further informed by [informant patrolman] that the defendant did not have a valid New York City Parks permit displayed for selling the tickets.
“[Deponent is] further informed by [informant [624]*624patrolman], that when he approached the defendant to ask for the defendant’s identification and to issue him a summons for the above conduct, the defendant pushed the [informant patrolman] about the chest, turned and ran away from [informant patrolman].
“When [deponent] attempted to arrest the defendant for the above conduct, the defendant was standing on a public road and the defendant flailed his arms by swinging his arms around his body, refused to place his arms behind his back, and attempted to run away from myself and the other officers. The defendant’s actions made it difficult to place the defendant in handcuffs without the assistance of three other officers and the use of OC spray.
“[Deponent] further observed that while arresting the defendant, a crowd of at least thirty people formed a circle around [deponent] and the defendant, and that the crowd was yelling at [deponent] and other officers, and that the crowd was standing in a public road. [Deponent] further observed that the crowd blocked the public roadway preventing at least ten vehicles from proceeding on the road.”

II. Procedural History

On May 28, 2015, the defendant was arraigned on a criminal complaint charging him with obstructing governmental administration in the second degree (Penal Law § 195.05), resisting arrest (Penal Law § 205.30), unlawful vending in a city park (56 RCNY 1-05 [b] [1]), and disorderly conduct (Penal Law § 240.20). At the arraignment, the defendant was released on his own recognizance and the court adjourned the case to July 23, 2015 for the People to file a supporting deposition. Off calendar, on June 9, 2015, the People served and filed a corroborating affidavit, a certificate of readiness and a voluntary disclosure form. Subsequently, on July 21, 2015, the defendant served and filed his omnibus motion including the instant motion to dismiss. On July 23, 2015, the defendant and his attorney appeared before the court. The court noted the People’s plea bargain offer, continued parole, and adjourned the case to September 21, 2015 for the People’s response and the court’s decision. On September 21, 2015, the defendant and his attorney appeared before the court. The People served and filed their response to the defendant’s omnibus motion, the court [625]*625noted the People’s plea bargain offer, and adjourned the case to November 9, 2015 for the court’s decision on defendant’s motions.

III. Discussion

Charged with obstruction of justice, resisting arrest, unlawful vending in a city park, and disorderly conduct, defendant moves to dismiss all counts on the ground of facial insufficiency. Defendant argues principally that the unlawful vending in a city park (56 RCNY 1-05 [b] [1]) count is facially insufficient because the information fails to allege that defendant’s conduct was not within the “expressive matter” exception (56 RCNY 1-05 [b] [2]) to unlawful vending in a city park. Defendant further argues that the remaining counts are facially insufficient because the defendant’s arrest for unlawful vending in a park was itself unlawful. In response, the People argue that selling tour tickets does not come under the “expressive matter” exception and, additionally, that the language in the complaint “sufficiently negates the [expressive matter] exception.” With respect to unlawful vending in a city park, the court finds that the “expressive matter” exception operates as a “proviso” that need not be negated in the accusatory instrument but may be raised by the accused in his defense at trial. As this was the only challenge to facial sufficiency, the court finds that all four counts of the information are facially sufficient.

A. Facial Sufficiency in General

A valid and sufficient accusatory instrument is a nonwaivable jurisdictional prerequisite to a criminal prosecution (People v Jackson, 18 NY3d 738, 741 [2012]). Since this defendant has not waived his right to be prosecuted by information, the court must assess his motion on the standards governing an information (People v Kalin, 12 NY3d 225, 228 [2009]).

An information is “sufficient on its face” when three requirements are met (CPL 100.40 [1]). One, the information must be in substantial conformity with CPL 100.15 which prescribes the form and content for informations, misdemeanor complaints and felony complaints (100.40 [1] [a]). Two, the “the reasonable cause” requirement demands that the factual allegations in the information and any supporting depositions “provide reasonable cause to believe that the defendant committed the offense charged” (People v Alejandro, 70 NY2d 133, 136 [1987]; CPL 100.40 [1] [b]). Reasonable cause to believe that a person has committed an offense “exists when evidence or information [626]*626which 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” (CPL 70.10 [2]). Three, the “prima facie case” requirement demands that the nonhearsay allegations of the information and supporting depositions “establish, if true, every element of the offense charged and the defendant’s commission thereof” (Alejandro at 136; CPL 100.40 [1] [c]).

A court reviewing for facial insufficiency must subject the allegations in the information to a “fair and not overly restrictive or technical reading” (People v Casey, 95 NY2d 354, 360 [2000]). The court must assume that the allegations are true (People v Konieczny, 2 NY3d 569, 575 [2004]; CPL 100.40 [1] [c]), and consider all “reasonable inferences” that may be drawn from them (Jackson at 747).

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Cite This Page — Counsel Stack

Bluebook (online)
50 Misc. 3d 622, 23 N.Y.S.3d 807, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-reddick-nycrimct-2015.