People v. Ware

148 Misc. 2d 943, 563 N.Y.S.2d 996, 1990 N.Y. Misc. LEXIS 619
CourtNew York Supreme Court
DecidedNovember 30, 1990
StatusPublished

This text of 148 Misc. 2d 943 (People v. Ware) is published on Counsel Stack Legal Research, covering New York Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Ware, 148 Misc. 2d 943, 563 N.Y.S.2d 996, 1990 N.Y. Misc. LEXIS 619 (N.Y. Super. Ct. 1990).

Opinion

OPINION OF THE COURT

Martin Marcus, J.

This decision considers whether, pursuant to a statutory amendment effective September 1, 1990, a defendant may bring a motion to "inspect and reduce” an indictment when his motion to "inspect and dismiss” that same indictment was made and denied long before the amendment’s effective date.

On April 17, 1989, a five-count indictment was filed against the defendant, the top count of which charged him with robbery in the second degree. That count alleges that on or about February 7, 1989, the defendant forcibly stole money from another person and that "in the course of the commission of the crime or in immediate flight therefrom, the defendant caused physical injury to that person, who was not a participant in the crime.”

The defendant was arraigned on the indictment on April 26, 1989, and made omnibus motions returnable June 15, 1989, including a motion pursuant to CPL 210.30 to inspect the Grand Jury minutes and to dismiss the indictment upon the ground that the evidence before the Grand Jury was legally insufficient to support the charges against him. On July 5, 1989, employing the statutory provisions then applicable, the Honorable William H. Wallace, III, denied the motion, finding the evidence sufficient to support the charges in the indictment "or any lesser included offenses.”

CPL 210.20 (1-a) and 210.30, as added and amended by Laws [945]*945of 1990 (eh 209), became effective September 1, 1990. Before then a court had only the authority to dismiss a count of an indictment for which the evidence before the Grand Jury was legally insufficient to support that count or any lesser included offense. These changes added authority to reduce a count for which the evidence is legally insufficient to a lesser included charge for which the evidence is sufficient. Relying on this new authority, the defendant now moves for inspection of the Grand Jury minutes and for a reduction of that count of the indictment charging him with robbery in the second degree to robbery in the third degree. As the basis for the reduction he seeks, the defendant alleges that the evidence before the Grand Jury was insufficient to establish that the complainant suffered "physical injury” within the meaning of Penal Law § 10.00 (9).

The preliminary question before the court is whether the new provisions to "inspect and reduce” should be applied retroactively in this case. The defendant claims that the statutory change is ameliorative and procedural in nature, and therefore should be applied retroactively. The People, on the other hand, contend that the statute is not ameliorative, and that the Legislature, by postponing the amendment’s effective date from its enactment in July until September 1, indicated an intent that the amendment not be applied retroactively. The two reported decisions which have thus far confronted this question have reached conflicting conclusions. (See, People v Davis, 148 Misc 2d 748 [Sup Ct, Queens County 1990] [deciding amendment not retroactive]; People v Levy, NYLJ, Oct. 2, 1990, at 26, col 3 [Sup Ct, Kings County] [applying amendment retroactively].)

The myriad of rules which govern retroactivity are often as difficult to state as they are to apply. Depending on how the nature of a statutory change is characterized, these rules create a presumption for or against retroactivity, which may be rebutted only by a clear expression of legislative intent for a different result. Since an explicit expression of legislative intent is often lacking, the direction of the presumption usually determines the outcome of the analysis.

Generally, statutes that are deemed "nonprocedural” are not given retroactive application unless there is a clear expression of legislative intent to the contrary. (See, e.g., Matter of Mulligan v Murphy, 14 NY2d 223, 226 [1964]; Matter of Ayman v Teachers’ Retirement Bd., 9 NY2d 119, 125 [1961].) However, when the Legislature makes a nonprocedural [946]*946change in a penal provision that is "ameliorative” in nature, that is, when it reduces the punishment for proscribed conduct, the opposite presumption applies: absent a clear expression of intent to the contrary, the change is applied retroactively. (See, People v Behlog, 74 NY2d 237, 240 [1989]; People v Oliver, 1 NY2d 152, 157 [1956].) On the other hand, a change that increases the penalty for criminal conduct may not be applied retroactively, whatever the Legislature’s intent, since such an application would violate the prohibition against ex post facto laws. (People v Oliver, 1 NY2d, supra, at 158.)

Statutes which are "procedural,” or curative in nature, or those which provide a remedy where none has previously existed, are also exceptions to the general rule against retroactive application. (McKinney’s Cons Laws of NY, Book 1, Statutes § 51 [b]; § 54.) Thus, as the defendant correctly notes, a procedural change made after conduct charged in an indictment was allegedly committed has generally been held applicable to the prosecution of that indictment. (See, People v Mandel, 61 AD2d 563 [2d Dept 1978], revd on other grounds 48 NY2d 952, 953 [1979], appeal dismissed 446 US 949, reh denied 448 US 908 [1980]; People v Nival, 33 NY2d 391, cert denied 417 US 903 [1974]; People ex rel. Pincus v Adams, 274 NY 447 [1937]; but see, People v Martinez, 82 Misc 2d 56 [Sup Ct, Kings County 1975] [procedural change which adversely affects substantial right of defendant violates ex post facto clause].) However, while procedural statutes are generally applied retroactively, this means only that they apply to pending proceedings, and that, "even with respect to such proceedings, they only affect procedural steps taken after their enactment. In other words, while procedural changes are generally deemed applicable to subsequent proceedings in pending actions, it takes a clear expression of legislative intent to justify a retroactive application of a procedural statute so as to affect proceedings previously taken in such actions” (McKinney’s Cons Laws of NY, Book 1, Statutes § 55).

In this case, as in most, whether the presumption favors or disfavors retroactivity will decide the question, since the Legislature expressed no clear intent either way, stating only that the new provisions "shall take effect September 1, 1990.” (L 1990, ch 209, §20 [3]; compare, L 1988, ch 744 [explicitly making its revisions of article 700’s eavesdropping provisions applicable only with respect to court orders or extensions issued on or after its effective date].) Admittedly, the Legislature’s decision to postpone the effective date for months after [947]*947its July enactment is some evidence of an intent against retroactivity. (See, Matter of Mulligan v Murphy, supra; People v Archer, 121 AD2d 730, 732 [1986].) Moreover, by placing the motion to "inspect and reduce” within the familiar omnibus motion framework of CPL article 255, it thereby required that such motions be made within the 45-day period required for omnibus motions, a period too short to permit retroactive application to most offenses committed within or before the statutory window between July and September. On the other hand, the postponement may instead have been intended only to provide the courts and litigants notice of the new procedure.

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Related

Ayman v. Teachers' Retirement Board
172 N.E.2d 571 (New York Court of Appeals, 1961)
People Ex Rel. Pincus v. Adams
9 N.E.2d 46 (New York Court of Appeals, 1937)
People v. Oliver
134 N.E.2d 197 (New York Court of Appeals, 1956)
Mulligan v. Murphy
199 N.E.2d 496 (New York Court of Appeals, 1964)
People v. McDowell
270 N.E.2d 716 (New York Court of Appeals, 1971)
People v. Nival
308 N.E.2d 883 (New York Court of Appeals, 1974)
People v. Mandel
401 N.E.2d 185 (New York Court of Appeals, 1979)
People v. Behlog
543 N.E.2d 69 (New York Court of Appeals, 1989)
People v. Mandel
61 A.D.2d 563 (Appellate Division of the Supreme Court of New York, 1978)
In re Derrick M.
63 A.D.2d 932 (Appellate Division of the Supreme Court of New York, 1978)
In re Robin B.
78 A.D.2d 679 (Appellate Division of the Supreme Court of New York, 1980)
People v. Cicciari
90 A.D.2d 853 (Appellate Division of the Supreme Court of New York, 1982)
People v. Thompkins
97 A.D.2d 593 (Appellate Division of the Supreme Court of New York, 1983)
People v. Archer
121 A.D.2d 730 (Appellate Division of the Supreme Court of New York, 1986)
People v. Martinez
82 Misc. 2d 56 (New York Supreme Court, 1975)
People v. Davis
148 Misc. 2d 748 (New York Supreme Court, 1990)

Cite This Page — Counsel Stack

Bluebook (online)
148 Misc. 2d 943, 563 N.Y.S.2d 996, 1990 N.Y. Misc. LEXIS 619, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-ware-nysupct-1990.