The People of the State of New York v Terell R. Wilson
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Attorneys and Parties
Brief Summary
Criminal procedure dispute over whether the prosecution's certificate of compliance (COC) under CPL article 245 [automatic criminal discovery provisions] was invalid because the People failed to disclose defendant's oral statements, thereby making the statement of readiness (SOR) ineffective for CPL 30.30 [statutory speedy trial rule] purposes.
County Court denied defendant's motion to dismiss on statutory speedy trial grounds and treated the challenge to the discovery violation as untimely, while also denying suppression and later entering judgments of conviction after a jury trial.
The Appellate Division rejected County Court's ruling that defendant's challenge could be denied as untimely and withheld decision on the convictions while remitting for further proceedings on whether the COC and SOR were proper.
The record did not adequately show whether the People exercised due diligence and made reasonable inquiries before filing the COC, which is the required inquiry when undisclosed discoverable statements may render a COC improper and an SOR illusory.
Background
Defendant was stopped at a sobriety checkpoint in Broome County around 1:40 a.m. on October 31, 2020. A state trooper suspected marihuana impairment and directed defendant to a secondary screening area, where events led to the discovery of a handgun and a physical struggle with troopers. After being taken into custody, defendant identified himself as another person. He was later charged in two indictments with obstructing governmental administration in the second degree, resisting arrest, criminal impersonation in the second degree and criminal possession of a weapon in the second degree. In September 2021, the People filed a certificate of compliance (COC) and statement of readiness (SOR). Defendant moved to suppress evidence from the checkpoint stop, but County Court denied suppression after a hearing at which a trooper testified to oral statements by defendant that had not been disclosed in discovery, including that he had smoked marihuana earlier that evening. Defendant then moved to dismiss on speedy trial grounds under CPL 30.30 [statutory speedy trial rule], arguing that the undisclosed statements showed the COC under CPL article 245 [automatic criminal discovery provisions] was illusory.
Lower Court Decision
County Court denied suppression, denied defendant's motion to dismiss under CPL 30.30, and found that although the People had not properly disclosed the oral statements, defendant's challenge was untimely. After trial, the jury convicted defendant of resisting arrest, criminal impersonation in the second degree and criminal possession of a weapon in the second degree. County Court sentenced him as a second violent felony offender to seven years in prison plus five years of postrelease supervision on the weapon conviction, with lesser concurrent terms on the other convictions.
Appellate Division Reversal
The Appellate Division held that County Court erred in denying the CPL 30.30 motion as untimely. The proper question was whether the undisclosed oral statements meant the People had failed to exercise due diligence and make reasonable inquiries before filing the COC under CPL article 245, which would render the SOR ineffective. Because the record was insufficient to resolve that issue, the court held the appeal in abeyance, reserved decision, and remitted the matter to County Court to determine whether the COC was proper and, if not, whether the People exceeded the applicable speedy trial time.
Legal Significance
The decision reinforces that readiness for trial under CPL 30.30 depends on a valid COC under CPL article 245. When discoverable material such as a defendant's oral statements is not disclosed, courts must analyze whether the prosecution exercised due diligence and made reasonable inquiries before filing the COC. A court may not dispose of that issue merely by labeling the defense challenge untimely, and the prosecution bears the burden of proving compliance.
An undisclosed oral statement can undermine a prosecution's certificate of compliance and statement of readiness. If the record does not show that the People acted with due diligence before certifying discovery compliance, an appellate court may remit for a full CPL article 245 and CPL 30.30 analysis rather than affirm the conviction outright.