People of the State of New York v Sir Charles Mosley IV
Attorneys and Parties
Brief Summary
Criminal procedure—statutory speedy trial and discovery compliance for trial readiness under CPL 30.30 [requires the People be ready for trial within six months in felony cases] and CPL 245.50 [the People are not deemed ready absent a proper certificate of compliance (COC), unless a court finds special circumstances].
Denied defendant’s CPL 30.30 motion, treating the People’s initial certificate of compliance as sufficient based on the prosecutor’s good faith.
The appellate court rejected the good-faith-only standard; it reserved decision and remitted for a due-diligence determination rather than affirming the denial.
Under People v Bay and CPL 245.50, the People must show due diligence and reasonable inquiries before filing a COC; good faith alone cannot validate readiness or stop the speedy-trial clock.
Background
A jury convicted defendant of criminal possession of a controlled substance in the third degree and resisting arrest. On appeal, defendant argued the People’s initial COC was improper because discoverable material was missing when filed, rendering their statement of readiness illusory and violating CPL 30.30.
Lower Court Decision
Supreme Court, Monroe County, denied the CPL 30.30 motion, concluding the People acted in good faith regarding discovery and accepting their initial COC and readiness.
Appellate Division Reversal
The Appellate Division held the trial court applied the wrong standard. It remitted for the court to determine whether the People exercised due diligence and made reasonable inquiries before filing the initial COC and, if appropriate, to assess whether the statement of readiness was valid and whether the People were ready within the six-month period.
Legal Significance
Reaffirms that a valid readiness under CPL 30.30 hinges on a proper COC under CPL 245.50. The People bear the burden to prove due diligence and reasonable inquiries; otherwise, readiness is illusory and time is chargeable to the People, potentially requiring dismissal.
Good faith is not enough. For felony cases, the People’s readiness requires a proper COC supported by due diligence and reasonable inquiries; courts must strike illusory readiness and, if the CPL 30.30 time is exceeded, dismiss.