People v. Campbell

2025 NY Slip Op 04352 · Appellate Division, Fourth Judicial Department · July 25, 2025 · No. 481 KA 21-01584

Summary

This New York Appellate Division opinion affirms a Monroe County Court judgment convicting the defendant of second-degree assault following a guilty plea. The defendant appealed, arguing that the trial court erred in denying his statutory speedy trial motion based on alleged discovery violations under CPL Article 245, and that he received ineffective assistance of counsel. The court found that the prosecution's failure to file a certificate of compliance did not warrant dismissal of the indictment and concluded that defense counsel provided meaningful representation without prejudice. Consequently, the court unanimously affirmed the conviction.

Court
Appellate Division, Fourth Judicial Department
Writing for the Court
Lindley, J.P.; Montour; Greenwood; Nowak; Keane
Jurisdiction
New York
Decision date
July 25, 2025
Docket number
481 KA 21-01584
Procedural posture
Appeal from a judgment of the Monroe County Court convicting defendant upon his guilty plea of assault in the second degree.
Precedential value
published
Parties
Chezere L. Campbell v. The People of the State of New York
Disposition
affirmed

Topics

speedy trialright to counselcriminal procedureappellate procedurestandard of review

Practice areas

criminal procedure

Questions Presented

  1. Whether the County Court erred in denying the defendant's motion to dismiss the indictment on statutory speedy‑trial grounds.
  2. Whether the defendant was deprived of effective assistance of counsel.

Holdings

  1. The Court held that the People were not required to file a certificate of compliance under CPL article 245, and the alleged discovery violation did not warrant dismissal of the indictment.
  2. The Court held that counsel preserved the speedy‑trial claim, obtained the victim's medical records in time, and provided meaningful representation, therefore no violation of the right to counsel occurred.

Key quotations

We conclude that the evidence, the law, and the circumstances of this case, viewed in totality and as of the time of the representation, reveal that defendant received meaningful representation. (at 1)

Factual background

Defendant Chezere L. Campbell pleaded guilty to assault in the second degree and was convicted by the Monroe County Court. He appealed, asserting that the trial court erred in denying his motion to dismiss the indictment on speedy‑trial grounds and that he received ineffective assistance of counsel.

Procedural history

The Monroe County Court convicted the defendant after a guilty plea to assault in the second degree. The defendant appealed, arguing speedy‑trial violations and ineffective assistance of counsel.

Court Document

Open PDF
Loading document…