People v. Robles, 66 N.Y.2d 931 (1985)
Knowledge of a defendant’s representation by counsel on a pending charge is not automatically imputed from the District Attorney’s office to the police, particularly when the pending indictment is old and there’s no evidence of communication or joint investigation between the prosecutor handling the new complaint and the police.
Summary
The New York Court of Appeals held that police officers were not deemed to have knowledge of the defendant’s representation on a prior, pending assault charge, even though the District Attorney’s office prosecuting that charge received a new complaint against the defendant. The court reasoned that, absent evidence of communication or a joint investigation between the DA’s office personnel handling the new complaint and the police, knowledge of representation is not imputed. This case highlights the limitations on imputing knowledge between different entities within the same prosecutorial system.
Facts
In April 1978, the defendant assaulted his stepdaughter. He was indicted for assault in July 1978 and released on bail, represented by counsel. In late August 1979, a new complaint accusing the defendant of sexually abusing his stepdaughter was referred to the county police by the same District Attorney’s office that was prosecuting the assault charge. The police officers were not informed that the defendant was represented by counsel on the assault charge. Two officers went to the defendant’s home, where he agreed to accompany them to the police station. The defendant subsequently made admissions and signed a confession regarding the sexual abuse allegations.
Procedural History
The defendant moved to suppress his confession, arguing that his waiver of counsel was ineffective because he was already represented on the pending assault charge. The County Court denied the motion to suppress. The defendant then pleaded guilty to rape in the second degree and sexual abuse in the second degree. The Appellate Division affirmed. The case then went to the New York Court of Appeals.
Issue(s)
Whether the knowledge of the District Attorney’s office regarding the defendant’s representation by counsel on a pending, unrelated charge should be imputed to the police officers who interrogated the defendant on a new charge, thereby rendering his waiver of counsel ineffective in the absence of his attorney.
Holding
No, because on the facts of this case, there was no basis for imputing knowledge of the defendant’s representation from the District Attorney’s office to the police officers.
Court’s Reasoning
The court distinguished this case from situations where knowledge is automatically imputed, emphasizing the lack of evidence showing the police had actual knowledge of the pending charge or the defendant’s representation. The court noted the 13-month gap between the initial indictment and the new complaint. The court stated, “There is no evidence that whoever handled the new complaint in the District Attorney’s office was personally aware of the pending charge or that there was any attempt to insulate its personnel or the police from such knowledge. Nor can it be said that the prosecutor’s cooperation with the police at this point was so extensive as to render the matter a joint investigation.” The court relied on prior precedent such as People v. Fuschino and People v. Servidlo in reaching its conclusion. The court refused to extend the imputation of knowledge doctrine to the facts presented, which lacked evidence of coordination or awareness between the different parts of the prosecutor’s office and the police.