People v. Coffey

Summary

The Appellate Division, Third Department withheld decision and remitted the matter to determine whether the prosecution's certificate of compliance was proper under the former version of CPL 245.50 and whether its statement of readiness was valid. The court held that the trial court improperly focused on prejudice rather than evaluating the prosecution's due diligence and good-faith compliance with discovery obligations.

Holdings

1. A defendant need not show prejudice to obtain dismissal on speedy-trial grounds based on the People's failure to timely comply with CPL article 245 discovery obligations.
2. The trial court must determine whether the People's initial certificate of compliance was filed in good faith and was reasonable under the circumstances despite the alleged discovery violations; that determination will establish whether the statement of readiness was valid.

Questions Presented

1. Whether County Court erred by denying defendant's CPL 30.30 speedy-trial motion based on a finding that defendant suffered no prejudice from the alleged discovery violations.
2. Whether the People's certificate of compliance was filed in good faith and was reasonable under the circumstances after due diligence and reasonable inquiries, and consequently whether the statement of readiness was valid.
3. Whether the case should be remitted because County Court did not determine whether the alleged discovery violations invalidated the certificate of compliance and statement of readiness.

Disposition

remanded