People v. Tyson

2025 NY Slip Op 00545
CourtAppellate Division of the Supreme Court of the State of New York
DecidedJanuary 31, 2025
Docket720 KA 24-00376
StatusPublished

This text of 2025 NY Slip Op 00545 (People v. Tyson) is published on Counsel Stack Legal Research, covering Appellate Division of the Supreme Court of the State 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. Tyson, 2025 NY Slip Op 00545 (N.Y. Ct. App. 2025).

Opinion

People v Tyson (2025 NY Slip Op 00545)
People v Tyson
2025 NY Slip Op 00545
Decided on January 31, 2025
Appellate Division, Fourth Department
Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431.
This opinion is uncorrected and subject to revision before publication in the Official Reports.


Decided on January 31, 2025 SUPREME COURT OF THE STATE OF NEW YORK Appellate Division, Fourth Judicial Department
PRESENT: SMITH, J.P., CURRAN, MONTOUR, GREENWOOD, AND HANNAH, JJ.

720 KA 24-00376

[*1]THE PEOPLE OF THE STATE OF NEW YORK, APPELLANT,

v

KENNETH TYSON, DEFENDANT-RESPONDENT.


MICHAEL J. KEANE, ACTING DISTRICT ATTORNEY, BUFFALO (MICHAEL J. HILLERY OF COUNSEL), FOR APPELLANT.

THE LEGAL AID BUREAU OF BUFFALO, INC., BUFFALO (ABIGAIL D. WHIPPLE OF COUNSEL), FOR DEFENDANT-RESPONDENT.



Appeal from an order of the Erie County Court (Susan M. Eagan, J.), dated January 29, 2024. The order granted the motion of defendant to dismiss the subject indictment.

It is hereby ORDERED that the order so appealed from is affirmed.

Memorandum: The People appeal from an order granting the motion of defendant to dismiss the indictment charging him with aggravated harassment of an employee by an incarcerated individual (Penal Law § 240.32) on the ground that he was denied his constitutional right of due process as a result of preindictment delay. Contrary to the People's contention, County Court did not err in granting the motion (see generally People v Taranovich, 37 NY2d 442, 444-445 [1975]).

Defendant was arrested on December 25, 2021 after an incident in which he threw urine at a correction officer attempting to enter defendant's cell while defendant was an inmate. He was indicted in February 2023. On November 24, 2023, defendant filed a motion to dismiss the indictment, arguing that his due process rights had been violated due to preindictment delay. On January 29, 2024, the court granted the motion and dismissed the indictment.

"By state and constitutional law, New York guarantees criminal defendants the right to a speedy trial and prompt prosecution" (People v Regan, 39 NY3d 459, 464 [2023]; see NY Const, art I, § 6; CPL 30.20). "[T]he State due process requirement of a prompt prosecution is broader than . . . the Sixth Amendment . . . [and] [i]n some respects the State rule is less rigid in its application than the right to due process recognized under the Federal Constitution" (Regan, 39 NY3d at 464 [internal quotation marks omitted]; see People v Singer, 44 NY2d 241, 253-254 [1978]). The Court of Appeals has "long held that unreasonable delay in prosecuting a defendant constitutes a denial of due process of law" and that "[a]n untimely prosecution may be subject to dismissal even though, in the interim, the defendant was not formally accused, restrained or incarcerated for the offense" (Singer, 44 NY2d at 253 [internal quotation marks omitted]). Further, there is no "fine distinction between due process violations based on delay in commencing prosecution[, i.e., preindictment delay,] and speedy trial violations, and the factors utilized to determine if a defendant's rights have been abridged are the same whether the right asserted is a speedy trial right or the due process right to prompt prosecution" (Regan, 39 NY3d at 465 [internal quotation marks omitted]). Those factors are: " '(1) the extent of the delay; (2) the reason for the delay; (3) the nature of the underlying charge; (4) whether or not there has been an extended period of pretrial incarceration; and (5) whether or not there is any indication that the defense has been impaired by reason of the delay' " (People v Wiggins, 31 NY3d 1, 9-10 [2018], quoting Taranovich, 37 NY2d at 445). " '[N]o one factor or combination of factors . . . is necessarily decisive or determinative of the [prompt prosecution] claim, but rather the particular case must be considered in light of all the [*2]factors as they apply to it' " (id. at 10, quoting Taranovich, 37 NY2d at 445; see Regan, 39 NY3d at 465) and, "if the first two factors favor [the] defendant, establishment of prejudice is not required to find a due process violation" (Regan, 39 NY3d at 471).

Under the circumstances, we conclude that the delay of 14 months between defendant's arrest and his indictment was unreasonable. The case was not complex and did not involve any unique theories of law. Additionally, the required evidence and witnesses—which consisted of employees of the Department of Corrections and Community Supervision (DOCCS) and evidence within DOCCS's possession—were available to the People at an early date (see e.g. People v Brown [appeal No. 2], 117 AD2d 978, 979-980 [4th Dept 1986]). We further reject the People's assertion that the laboratory testing caused a delay in this case. Upon receipt of a "Bioscience Request for Priority Case Status," the testing of the liquid thrown at the correction officer was completed within one month. Further, the People's delay in obtaining an indictment in this matter could not have been based upon the need for the lab report inasmuch as the report was completed before law enforcement filed the paperwork with the People. We reject the People's remaining allegation of delay for good cause (see generally Regan, 39 NY3d at 474).

We conclude that the third factor, i.e., the nature of the underlying crime, also weighs in defendant's favor. The legislature has deemed this offense to be a class E felony—the lowest level of felony offense (see Penal Law § 240.32). The third factor also requires that we consider the complexity of the crime and, for the reasons noted above, "the preparation to which the People attribute a delay for the prosecution of this crime was not complex" (Regan, 39 NY3d at 470).

We reject the People's contention that the fourth factor—i.e., whether defendant was subjected to a period of incarceration during the delay—weighs in their favor. Although defendant was serving a sentence on an unrelated charge at the time the incident occurred, defendant was placed in solitary confinement for seven months as a result of this incident. Further, where, as here, the defendant is imprisoned on another crime, that imprisonment "cannot excuse the delay" (Singer, 44 NY2d at 254).

Inasmuch as "the first two factors favor defendant, establishment of prejudice is not required to find a due process violation" (Regan, 39 NY3d at 471). In any event, the Court of Appeals, in addressing similar facts, has noted that the delay in charging an incarcerated individual with a subsequent crime may prolong their "incarceration, as a practical matter, by foreclosing the possibility of a concurrent sentence" (Singer, 44 NY2d at 253), and "may also interfere with [their] rehabilitation, particularly when [they are] already aware that [they are] suspected or 'known' to have committed the other offense" (id. at 254). That is exactly the prospect defendant faced here.

All concur except Curran and Greenwood, JJ., who dissent and vote to reverse in accordance with the following memorandum: We respectfully dissent and vote to reverse, deny the motion to dismiss, and reinstate the indictment because, in our view, defendant was not deprived of due process by unreasonable preindictment delay (see generally NY Const, art I, § 6).

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Cite This Page — Counsel Stack

Bluebook (online)
2025 NY Slip Op 00545, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-tyson-nyappdiv-2025.