Westchester Rockland Newspapers, Inc. v. Leggett, 48 N.Y.2d 985 (1979)

When providing public access to pre-trial proceedings, while a court may offer redacted transcripts, the responsibility for the redaction itself is a nondelegable duty of the court.

Summary

This case concerns the balance between the public’s right to know and a defendant’s right to a fair trial, specifically regarding access to pre-trial suppression hearings. The Court of Appeals affirmed the lower court’s decision to allow access to transcripts, but clarified that while the court can offer redacted transcripts to the press, the actual act of redacting inadmissible evidence is the court’s responsibility, not that of the District Attorney or defense counsel. The court also cautioned against staying trial proceedings for collateral appeals regarding public access, emphasizing the defendant’s right to a speedy trial.

Facts

The case arose from pre-trial motions in a criminal case. The trial court determined to allow the press access to transcripts of the pre-trial proceedings. The court offered to supply complete transcripts of the proceedings during the pretrial motions, except for the redacted portions of yet inadmissible admissions of the defendant. The court stated that the redacting “has to be done by the District Attorney and defense counsel because the court doesn’t have the time”. The trial court then stayed its proceedings pending the determination of this appeal.

Procedural History

The trial court decided to allow press access to redacted transcripts of pre-trial proceedings and stayed the trial pending appeal of that decision. The Appellate Division’s decision was affirmed by the Court of Appeals.

Issue(s)

1. Whether a trial court can delegate the responsibility of redacting inadmissible portions of pre-trial transcripts to the District Attorney and defense counsel when providing those transcripts to the press.
2. Whether a trial court should stay its proceedings pending the determination of an appeal regarding press access to redacted transcripts, potentially impacting the defendant’s right to a speedy trial.

Holding

1. No, because the redaction of transcripts is a nondelegable responsibility of the hearing court itself.
2. No, because the right of a defendant to a speedy trial is important and should not be sacrificed in the name of collateral appeals, except in rare situations not present here.

Court’s Reasoning

The Court of Appeals affirmed the allowance of public access to the transcripts, referencing Matter of Gannett Co. v De Pasquale, which emphasized balancing public knowledge with fair trial rights via redacted transcripts. However, the Court explicitly stated that while a court may offer redacted transcripts, performing the redaction is the “nondelegable responsibility of the hearing court itself”. The court reasoned that delegating this responsibility was inappropriate. Further, the Court cautioned against staying proceedings for collateral appeals, stressing the importance of a defendant’s speedy trial rights. The court recognized the broad discretion of trial courts to stay their own proceedings, but cautioned that the right of a defendant to a speedy trial is important and should not be sacrificed in the name of these collateral appeals. The Court found the stay in this case was not justified, highlighting that the defendant had been incarcerated since September 1978, awaiting trial, which had been delayed due to the collateral matter. The court stated, “Only in rare situations, not present here, should a court stay trial proceedings to permit a challenge to rulings permitting the press and public to have redacted transcripts of pretrial suppression proceedings.”