People v. Mendez

Summary

The New York Court of Appeals held that the trial court committed reversible error by failing to disclose or respond to jury notes requesting translated transcripts of recorded jail calls. The court reversed the order of the Appellate Division and dismissed the indictment, while permitting the People to resubmit the assault charge to a new grand jury.

Holdings

1. The jury's requests for the transcripts required a substantive response because the transcripts were necessary to understand significant portions of the recordings and the trial court had expressly invited the jury to request them during deliberations.
2. Reversal was required because the substantive jury notes were neither revealed to the attorneys nor addressed by the trial court.

Questions Presented

1. Whether the trial court's failure to disclose to counsel and address the jury's substantive requests for Spanish-to-English transcripts of recorded telephone calls required reversal.
2. Whether the jury's requests could be treated as merely ministerial requests for items not admitted into evidence.

Disposition

reversed_and_remanded