People v. Goins, 73 N.Y.2d 983 (1989)
A delay in disclosing Rosario material (prior statements of a prosecution witness) that prejudices the defendant’s trial strategy warrants a new trial.
Summary
The defendant was convicted of burglary, sodomy, and related offenses. His defense hinged on inconsistencies in the complainant’s statements. The prosecution, aware of a memo book entry from a hospital interview with the complainant that corroborated her trial testimony, did not disclose it until after the defense had built its strategy around the statement’s supposed non-existence. This late disclosure significantly undermined the defense’s strategy, as it rehabilitated the complainant’s credibility. The New York Court of Appeals reversed the Appellate Division order and ordered a new trial, holding that the delayed disclosure of the Rosario material prejudiced the defendant.
Facts
The defendant was charged with burglary, sodomy, and related offenses. The complainant provided an initial statement to the police. Later, she was interviewed at the hospital. The arresting officer testified about interviewing the complainant in her apartment and at the hospital. He stated that the hospital interview did not cause him to change his original memo book entry. The prosecutor knew of a memo book entry memorializing the hospital interview. The prosecutor elicited testimony that the complainant’s hospital version was substantially similar to her trial testimony.
Procedural History
The defendant was convicted at trial. The defense appealed, arguing that the delayed disclosure of Rosario material prejudiced his defense. The Appellate Division affirmed the conviction. The New York Court of Appeals reversed the Appellate Division’s order and ordered a new trial.
Issue(s)
Whether the People’s delay in disclosing Rosario material (a prior consistent statement of the complaining witness) until after the defense had committed to a particular trial strategy prejudiced the defendant to warrant a new trial.
Holding
Yes, because the delayed disclosure of the statement recorded in the hospital prejudiced the defendant substantially by undermining his defense strategy which depended on the statement’s nonexistence and rehabilitated the complaining witness’s credibility.
Court’s Reasoning
The Court of Appeals relied on the principles established in People v. Perez, 65 N.Y.2d 154, 159 (1985); People v. Ranghelle, 69 N.Y.2d 56 (1986); and People v. Rosario, 9 N.Y.2d 286, 289 (1961). The court reasoned that the prosecution’s failure to disclose the memo book entry memorializing the hospital interview prejudiced the defendant’s ability to effectively cross-examine the complaining witness and construct his defense. The defense strategy was based on highlighting inconsistencies between the complainant’s initial version and her later testimony. The undisclosed memo book entry, which corroborated her trial testimony and refuted any claim of recent fabrication, directly undermined this strategy. By the time the defense learned of the memo book entry, they had already committed to a line of questioning that was severely weakened by the new information. The court emphasized that the “People’s delay in turning over the statement recorded in the hospital — revealed as it was only after defense counsel had moved forward on a strategy that depended on the statement’s nonexistence — substantially prejudiced the defendant.” This prejudice warranted a new trial to ensure the defendant had a fair opportunity to present his defense with full knowledge of the evidence against him.