Matter of State of New York v. King, 36 N.Y.2d 59 (1974)
The extraordinary remedy of prohibition is available only when a court acts without jurisdiction or exceeds its authorized powers, and is not a means to seek collateral review of an error of law in a pending criminal action.
Summary
This case addresses the appropriate use of a writ of prohibition to challenge a lower court’s decision. The Court of Appeals held that prohibition is not available to correct mere errors of law within a court’s jurisdiction; it is reserved for instances where a court lacks jurisdiction over the subject matter or acts in excess of its authorized powers. The court reversed the Appellate Division’s decision, finding that the petition alleged only an error of law, not a jurisdictional defect, and therefore should have been dismissed. The decision emphasizes the limited scope of prohibition as a remedy.
Facts
The defendant in a criminal case was ordered by the Supreme Court to provide the prosecution with a written report of an examination conducted by a court-appointed psychiatrist. The defendant then sought a writ of prohibition to prevent the Supreme Court from enforcing that order.
Procedural History
The defendant filed a petition for article 78 relief, in the nature of prohibition, in the Appellate Division. The Appellate Division ruled in favor of the defendant, preventing the Supreme Court from requiring the report. The State of New York appealed to the Court of Appeals.
Issue(s)
Whether the Appellate Division erred in granting a petition for a writ of prohibition to prevent the Supreme Court from requiring a defendant to provide the prosecution with a written report of his examination by a court-appointed psychiatrist.
Holding
Yes, because the extraordinary remedy of prohibition lies only where a court acts without jurisdiction or exceeds its authorized powers, and is not available as a means of seeking collateral review of an error of law in a pending criminal action.
Court’s Reasoning
The Court of Appeals stated that prohibition is an extraordinary remedy that is only available in limited circumstances. Citing Matter of State of New York v King, 36 NY2d 59, 62, the court reiterated that prohibition lies only where a court “acts or threatens to act without jurisdiction in a matter over which it has no power over the subject matter or where it exceeds its authorized powers in a proceeding over which it has jurisdiction.” The court emphasized that prohibition is not a substitute for appeal and cannot be used to correct errors of law. The court found that the defendant’s petition alleged no more than an error of law, and therefore the remedy of prohibition was not appropriate. The court did not address the merits of the underlying claim regarding the report from the psychiatrist, as the procedural issue was dispositive. The court emphasized the importance of maintaining the separation of powers and preventing unwarranted interference with ongoing judicial proceedings through the misuse of extraordinary remedies.