People v. Williams, 73 N.Y.2d 84 (1988)
A Grand Jury whose term has been extended under CPL 190.15(1) due to uncompleted business may not consider entirely new matters during its extended term, and an indictment resulting from such a violation must be dismissed.
Summary
This case addresses the permissible scope of a Grand Jury’s power when its term has been extended. The Court of Appeals held that a Grand Jury extended to complete unfinished business could not consider new matters. The case stemmed from allegations of witness tampering in a rape case, which were investigated by a Grand Jury whose term was extended. The Court found that because the extended Grand Jury considered new matters unrelated to its original business, the resulting indictment was invalid and must be dismissed without requiring a showing of prejudice to the defendants. The decision emphasizes adherence to statutory limitations on Grand Jury power.
Facts
Shelly McClure accused her stepfather, Martin Williams, of rape. Donna Williams, McClure’s mother, urged her to withdraw the charges. McClure recanted her accusation in exchange for $3,000, signing a recantation statement prepared by attorney Michael Barrett. Jeffrey Snyder, McClure’s boyfriend, was also involved. Subsequently, attorney Robert Becher pressured McClure to reaffirm her recantation. These events led to an investigation into bribery, conspiracy, and witness tampering.
Procedural History
A Rensselaer County Grand Jury, nearing the end of its term, had its term extended to investigate the witness tampering allegations. The Grand Jury indicted the defendants. The trial court dismissed the indictment, finding the extended Grand Jury exceeded its jurisdiction. The Appellate Division reversed, reinstating the indictment. The Court of Appeals reversed the Appellate Division, reinstating the trial court’s dismissal.
Issue(s)
1. Whether a Grand Jury whose term has been extended under CPL 190.15(1) may consider entirely new matters during its extended term.
2. Whether an indictment resulting from a Grand Jury considering new matters during its extended term must be dismissed.
Holding
1. Yes, because CPL 190.15(1) limits Grand Jury extensions to completing unfinished business; considering new matters exceeds this statutory authority.
2. Yes, because a Grand Jury acting outside its authorized scope is considered “illegally constituted” under CPL 210.35(1), mandating dismissal regardless of prejudice.
Court’s Reasoning
The Court reasoned that CPL 190.15(1) explicitly limits Grand Jury extensions to completing unfinished business, curtailing a holdover Grand Jury’s jurisdiction. The Court distinguished its prior holding in People v. Stern, noting that the Criminal Procedure Law now contains specific provisions governing Grand Jury extensions that did not exist previously. The court emphasized that the plain language of the statute limits extensions to those necessary to complete unfinished business. Because the Grand Jury did not begin investigating the McClure matter until after its original term expired, the court found that the extension was improper. The Court also stated, “[T]he statute’s plain language limits Grand Jury extensions to those that are necessary to permit the completion of unfinished business. The statute thus has the substantive effect of curtailing a holdover Grand Jury’s jurisdiction. The apparent purpose was to eliminate the danger of ‘vestpocket’ Grand Juries”. Further, the court reasoned that CPL 210.35 mandates dismissal when the Grand Jury is “illegally constituted.” Because the Grand Jury exceeded its statutory authority, the indictment was invalid, and dismissal was required regardless of whether the defendants suffered prejudice. The Court emphasized that certain improprieties, such as those delineated in CPL 210.35(1)-(3), require automatic dismissal, whereas other, less serious infractions of Article 190 rules require a showing of prejudice to the accused.