Tagged: criminal procedure

Getting Particular

There’s a great post today on the New York Criminal Defense blog, explaining the history and proper use of the Bill of Particulars in NY criminal practice. Our readers are encouraged to check it out here.

This has long been a pet peeve of ours. An astounding number of prosecutors just don’t get the concept of a Bill of Particulars in this state. And far too few defense attorneys and judges hold the People to their obligations here.

Which is bizarre, because it’s really quite simple. All the Bill needs to do is specify what facts the People intend to prove which make out the elements of the crimes charged in the indictment, without explaining how the People intend to prove those facts.

For example, a buy-and-bust with stash and cash might have a Bill that states, at such-and-such time and place, “the defendant handed to an undercover police officer two bags containing crack cocaine in exchange for money. Twenty-four bags containing crack cocaine were recovered from the ground where the defendant threw them.” That’s all that’s needed. No mention is required of how the People will prove the stuff is crack, or anything about the money that was recovered, or anything else.

And yet prosecutors keep doing it wrong. We routinely get Bills of Particular that contain nothing more than bare conclusions of law, such as “the defendant sold crack cocaine to a police officer and possessed crack cocaine with the intent to sell it.” Or worse than that, just a recitation of the time, date and location, and an assurance that the indictment contains all the information that is needed.

Failure to provide a sufficient Bill renders the indictment defective. We’re amazed that more defense counsel don’t pursue this aggressively, and educate their judges who may be a little complacent given the lack of rigor by many attorneys.

Once again, we highly recommend this article to our readers. It was written, by the way, by Jill Paperno of the Monroe County Public Defender’s office, so kudos to Jill.

Defense Wins by Losing: Supreme Court Overrules Michigan v. Jackson

In a perhaps not-all-that-important decision this morning, the Supreme Court overruled a landmark case involving the Sixth Amendment right to counsel. Although it seems like a big deal, today’s decision doesn’t really seem to change anything. Criminal procedure is not likely to change. The upshot is that the police still...

Supreme Court Undoes Belton, Dramatically Limits Car Searches

In a stunning 5-4 decision, the Supreme Court today reversed its longstanding bright-line rule which had permitted warrantless car searches after an arrest, even when there was no concern for officer safety or the preservation of evidence. The case is Arizona v Gant. Writing for the majority in this important...

Supreme Court Messes Up — Fails to Clarify Misunderstood Miranda

We admit it: we like to skip to the Scalia dissent. Not because we necessarily agree with his philosophy of jurisprudence. But because it’s a good bet to be an entertaining read. Whether he’s dissenting from an expansive activist or a fellow limited-role jurist, he’s good for a bit of...

Assigned Counsel are Not Government Actors? This is News?

The Supreme Court ruled today that defense attorneys assigned by the state are not government actors, merely because the government assigns and pays them. They are attorneys for the defendant, and their actions are actions of the defense, not the government. This seems like a no-brainer. Every defense attorney knows...

More Allegations of Prosecutorial Misconduct in Sen. Ted Stevens Case

First, a recap: Last July, former Alaska Senator Ted Stevens was indicted on seven counts of failing to report gifts he’d received, including renovations to his house in excess of what he’d paid for, but mostly goods and services from oil tycoon Bill Allen. Sen. Stevens pled not guilty, and...

Gang Crime Rising, So More… White-Collar Prosecutions?

Gang crime is on the rise, the FBI reports. The politicians and prosecutors, however, are focusing on white-collar crime these days. Here’s a look at why this is happening. Gang crime seems to have increased, ironically, as a result of improved anti-gang law enforcement in the big cities. According to...

African Union Asks Security Council to Quit on Darfur

As previously reported, the ICC prosecution of Sudan’s leader Omar al-Bashir has had its share of challenges. Yesterday, the African Union threw another monkey wrench into an already shaky machinery. The African Union is an international organization of all African nations except Morocco. The organization, which is expected to name...

Supreme Court Expands “Stop and Frisk” Authority

On Monday, a unanimous Supreme Court reiterated its rule that a police officer may pat down the passenger of a car that was stopped for a traffic infraction, if the officer has reason to believe the passenger is armed and dangerous. The Court also added that the authority to conduct...

We’re Not Alone

  Yesterday, we observed that there have been a lot of Ponzi schemes coming down lately, and asked what gives? Today, the Wall Street Journal made the same observation, and asked the same question. Here are some points from the article: * In 2007, the SEC had brought civil actions...

Yet Another Massive Ponzi Scheme Alleged. What’s that tell you?

Nick Cosmo, the 37-year-old head of Agape World Inc. and Agape Merchant Advance, was arraigned today on charges that he ran a Ponzi scheme that cheated investors out of $370 million since 2006. The feds allege that about 1,500 investors were promised annual returns of as much as 80%. These...

Second Circuit Refuses to Limit Corporate Criminal Liability

White-collar prosecutors and defense attorneys have been keenly awaiting today’s decision in U.S. v. Ionia Management. At oral arguments last November, the court permitted amicus filer Andrew Weissmann (former head of the Enron Task Force) to make a case for limiting the criminal liability of corporations. The fact that he...

“Not With Me, They Don’t” – Race Not a Factor in Sentence, Says Judge

  District Court Judge Percy Anderson sentenced Jeanetta Standefor to more than 12 years in prison on Tuesday, for running an $18 million Ponzi scheme that preyed on middle-class black investors. Standefor, who is also black, solicited investments from 650 people around Pasadena who thought the money would go to...

Justices Miss the Point of the Exclusionary Rule

The Bill of Rights, notably Amendments 4-6, protects accused individuals from improper action by the police. The typical remedy for police violation of these rights is suppression of the evidence that would not have been gathered but for the violation. This Exclusionary Rule protects the justice system, by ensuring that...

Supreme Court: Failure to Surrender ? Escape

This morning, the Supreme Court returned from its long break to issue a unanimous ruling in Chambers v. United States (No. 06-1120, Jan. 13, 2009). At issue was the crime of failure to report to jail, and whether that crime is a “violent felony” for the purposes of the Armed...