People v. Victory

166 Misc. 2d 549, 631 N.Y.S.2d 805, 1995 N.Y. Misc. LEXIS 420
CourtCriminal Court of the City of New York
DecidedAugust 4, 1995
StatusPublished
Cited by17 cases

This text of 166 Misc. 2d 549 (People v. Victory) 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. Victory, 166 Misc. 2d 549, 631 N.Y.S.2d 805, 1995 N.Y. Misc. LEXIS 420 (N.Y. Super. Ct. 1995).

Opinion

OPINION OF THE COURT

Joseph J. Maltese, J.

In view of the Court of Appeals 4 to 3 split decision in People v Atkins (85 NY2d 1007 [1995]), this court, upon the application of the People, has reconsidered its decision of June 6, 1995 which suppressed the results of a breathalyzer test, and hereby sets it aside.

This court now holds that in this prosecution of Vehicle and Traffic Law § 1192 for operating a motor vehicle while impaired or intoxicated by alcohol, upon objection of the defense, the prosecution must establish, at a hearing by expert testimony, scientific evidence that a blood-alcohol content (BAG) test taken more than two hours after the arrest of the defendant is competent, reliable and probative of the fact that the defendant was impaired or intoxicated when he operated a motor vehicle before such results may be admitted as relevant evidence at the trial.

Recently, the Court of Appeals in Atkins (supra) allowed a BAG test for drugs to be admitted into evidence when the defendant consented to take the test within two hours of arrest, and where the test was actually administered 2 hours and 28 minutes after the arrest. More recently, Judge Grosso, in People v Capraella (165 Misc 2d 639 [Crim Ct, Queens County 1995]), denied a motion to suppress the results of a BAG test administered after two hours, and held that Atkins eliminated the two-hour rule when a defendant expressly consents to take the BAG test. However, Judge Grosso stated that it was unclear whether Atkins only applies where the defendant consents to [551]*551take a BAG test within two hours of arrest. Both Judge Grosso and this court believe that the Court of Appeals in Atkins has created more questions than answers to the Vehicle and Traffic Law § 1194 two-hour rule. Hence a review of the two-hour rule is appropriate to understand and place Atkins in its proper perspective.

THE TWO-HOUR RULE

Under Vehicle and Traffic Law § 1194 (2) and the New York State Department of Health Regulations (10 NYCRR 59.2 [c] [2]) regarding the administration of blood and breath tests it is mandated that the BAG test shall be administered within two hours of arrest.1

The two-hour rule actually benefits the prosecution in that it creates a presumption that the BAG test results are admissible. Absent such a rule the prosecutor would need to establish by expert testimony the scientific relevancy of the test in every drunk driving prosecution. Since the Court of Appeals in Atkins (supra) will allow evidence of a BAG test taken more than two hours from arrest to be presented in a trial, the People lose their presumption of the scientific reliability beyond two hours from arrest and must now establish same at a pretrial hearing.

Prior to the Court of Appeals decision in Atkins (supra) all of the Appellate Divisions and the various trial courts had rendered numerous disparate published decisions regarding the interpretation of the two-hour rule. Despite the conflicting [552]*552views, the Court of Appeals in Atkins, a 4 to 3 majority memorandum decision, sheds little guidance on the interpretation of the two-hour rule. Only the dissent discusses the issues. In affirming the unreported decision of the First Department, Appellate Term’s affirmance of an unreported New York County Criminal Court decision, the Court of Appeals relied upon People v Ward (307 NY 73 [1954]).

In Ward (supra), the 1954 Court of Appeals stated that "actual consent” nullifies "implied consent”. While this may be true, the Court of Appeals in Ward was not discussing the "two-hour rule.” In fact, the "implied consent” statute (Vehicle and Traffic Law former § 71-a) and the two-hour rule (Vehicle and Traffic Law former § 70 [5]) were in different parts of the statute.2

Moreover, the issue of the nonvoluntariness of the defendant’s consent was not even addressed by the Court in Atkins as it was not preserved for appeal (see, People v Atkins, supra, at 1009, n 2).

The Appellate Term, First Department’s holding in People v Atkins (order No. 94-048, June 22, 1994) relied heavily upon the case of People v Mills (124 AD2d 600 [2d Dept 1986], lv denied 69 NY2d 953 [1987], supra) which since its decision in 1987 has been cited numerous times for the proposition that the results of a chemical blood-alcohol content test administered beyond two hours after the defendant’s arrest may be admitted into evidence, as long as the defendant consented to the test.3

[553]*553PEOPLE v MILLS

However, the Second Department of the Appellate Division in Mills (supra) was affirming a Penal Law conviction to reckless vehicular homicide, not the extension of the two-hour rule of the Vehicle and Traffic Law. As Judge Tallmer, a Criminal Court Judge in the First Department, stated in People v Edwards (NYLJ, May 12, 1992, at 26, col 6 [Crim Ct, NY County]): "[Mills (supra)] is distinguishable on its facts. In Mills, defendant was charged with criminally negligent homicide, not driving while intoxicated. Thus, the Appellate Division’s holding that the two-hour rule does not apply where express consent is given is dicta as to whether compliance with the two-hour rule must be proven by the People as an element of the crime of driving while intoxicated” (emphasis added).

Unfortunately, such facts were not clear in the one-page memorandum decision affirming the conviction. As a result, Mills (supra) has been consistently misread and misapplied since its issuance. Only a reading of the appellate record places the Mills decision in its proper context, the affirmance of a negotiated plea to vehicular homicide. Since the two-hour rule in a Vehicle and Traffic Law case was not ruled upon in Mills, it may be distinguished from the typical DWI case where the two-hour rule applies.

The facts in Mills (supra) demonstrate the old legal adage by Justice Holmes that hard facts make bad law.4 Harry Mills, Jr. was a college student and the son of a Town Justice who was driving an automobile which was involved in an accident which left a mother of two dead.5 After Mills pleaded guilty to criminally negligent homicide (Penal Law § 125.10) and received what may be argued is a light sentence,6 the defendant appealed the sentence and all decisions made on prior motions, including a decision holding all provisions of Vehicle and Traffic Law § 1194, including the two-hour rule, inapplic[554]*554able as the case involved the Penal Law and not the Vehicle and Traffic Law.

The trial court held that "[t]he requirements of the Vehicle and Traffic Law § 1194 are not relevant [and therefore] the test results will only be admissible if obtained with the defendant’s consent or pursuant to a court order” (MR 73).7 The trial court then held that CPL 60.758

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Cite This Page — Counsel Stack

Bluebook (online)
166 Misc. 2d 549, 631 N.Y.S.2d 805, 1995 N.Y. Misc. LEXIS 420, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-victory-nycrimct-1995.