People v. Deegan, 69 N.Y.2d 976 (1987)
The standard for reviewing the sufficiency of evidence to support an indictment is whether the evidence is legally sufficient, meaning competent evidence that, if accepted as true, would establish every element of the offense charged; it requires a prima facie showing, not proof beyond a reasonable doubt.
Summary
Defendant, an elected official, was indicted for allegedly changing his vote on a waste removal rate increase in exchange for promised campaign contributions. The lower courts dismissed the indictment, finding the evidence insufficient by applying an incorrect standard requiring exclusion of every hypothesis but guilt to a moral certainty. The Court of Appeals reversed, holding that the proper standard for an indictment is legal sufficiency, meaning a prima facie case. The Court emphasized that it is the Grand Jury’s role to determine reasonable cause, and the ‘moral certainty’ standard applies only at trial.
Facts
The defendant, an elected official, allegedly changed his vote on a proposed rate increase for waste removal services. This change purportedly occurred after a promise of future campaign contributions from members of the waste removal industry. The Grand Jury subsequently indicted the defendant based on this evidence, including declarations of an alleged co-conspirator.
Procedural History
The trial court dismissed the indictment, deeming the evidence insufficient. The Appellate Division affirmed the dismissal. The Court of Appeals reversed the Appellate Division’s order, reinstated the indictment, and remitted the matter to the trial court for further proceedings.
Issue(s)
Whether the evidence presented to the Grand Jury was legally sufficient to support the indictment against the defendant for changing his vote in exchange for promised campaign contributions.
Holding
Yes, because the evidence before the Grand Jury was legally sufficient, meaning it constituted competent evidence that, if accepted as true, would establish every element of the offense charged, thereby meeting the prima facie standard for an indictment.
Court’s Reasoning
The Court of Appeals held that the lower courts erred by applying an incorrect standard of proof for evaluating the sufficiency of the evidence supporting the indictment. The lower courts had relied on a standard requiring the exclusion of every hypothesis but guilt to a moral certainty, which is not the standard for evaluating indictments. The Court explicitly stated, “As we held in People v Jennings (supra, at 114-116), the proper standard for reviewing the sufficiency of the evidence to support an indictment is ‘legal sufficiency,’ which is defined in CPL 70.10 (1) as ‘competent evidence which, if accepted as true, would establish every element of an offense charged’ (see, CPL 190.65 [1]).” The court further clarified that “legally sufficient means prima facie, not proof beyond a reasonable doubt” (quoting People v Mayo, 36 NY2d 1002, 1004). The Court emphasized that the Grand Jury is responsible for determining whether there is reasonable cause to believe a crime was committed and that the ‘moral certainty’ standard is applicable only to the trier of fact at trial. The court found that even excluding the alleged coconspirator’s declarations, the remaining evidence was sufficient to infer the defendant changed his vote for a promise of future campaign contributions. The Court declined to rule on the admissibility of other disputed evidence, deeming it premature. Because the inquiry on a motion to dismiss an indictment for insufficient evidence is purely legal, the court rejected remitting the appeal to the Appellate Division for further factual review, since the Grand Jury evidence met the legal sufficiency standard.