People v. Lancaster, 85 N.Y.2d 203 (1995)
A prosecutor may interrupt a defendant’s grand jury testimony to focus the testimony on relevant matters without impairing the integrity of the proceedings, as long as the defendant is given a fair opportunity to present their version of events.
Summary
Lancaster was indicted for criminal sale of a controlled substance and unlawful possession of marihuana. The Supreme Court dismissed the indictment, finding that the prosecutor interfered with Lancaster’s testimony before the Grand Jury. The Appellate Division reversed. The New York Court of Appeals affirmed the Appellate Division’s decision, holding that the prosecutor’s interruptions were permissible because they sought to focus Lancaster’s testimony on the relevant issue of whether she sold drugs or acted as an agent, and did not deprive her of a fair opportunity to present her version of events. The court emphasized that testimony before the Grand Jury should concern “relevant and competent evidence concerning the case under consideration.”
Facts
On December 17, 1992, an undercover officer approached Lancaster, who asked if he was “looking to get nice.” After the officer indicated he was looking for “two nickels,” Lancaster led him to a location, took $10 from him, and returned with one vial of alleged “crack” cocaine. The officer, who had requested “two nickels,” asked for the other vial, but Lancaster stated that “they only had dimes.” Another officer then arrested Lancaster, and a search revealed small quantities of cocaine and marihuana.
Procedural History
Lancaster was indicted for criminal sale of a controlled substance and unlawful possession of marihuana. She moved for court inspection of the Grand Jury minutes and dismissal of the indictment. The Supreme Court dismissed the indictment, finding prosecutorial interference with Lancaster’s testimony, with leave for the District Attorney to re-present the matter to the Grand Jury. The Appellate Division reversed and reinstated the indictment. The Court of Appeals affirmed the Appellate Division’s order.
Issue(s)
- Whether a prosecutor’s interruptions of a defendant’s Grand Jury testimony, in an effort to focus the testimony on relevant matters, constitute an impairment of the integrity of the Grand Jury proceedings.
Holding
- No, because a defendant must be given an opportunity to give her version of the events, but that testimony should be regarding “relevant and competent evidence concerning the case under consideration.”
Court’s Reasoning
The Court of Appeals held that the prosecutor’s interruptions did not deprive Lancaster of the opportunity to make her statement regarding the charges against her. The court cited CPL 190.50 (5) (b), which states that a defendant must be permitted to testify before the grand jury and give any relevant and competent evidence concerning the case under consideration. The court found that Lancaster spoke at length about her past and drug addiction, and the prosecutor sought to focus her attention on whether she was acting in concert or as an agent of the buyer. The court reasoned that requesting Lancaster to confine her statements to facts relevant to whether she sold drugs or acted as an agent did not abridge her right to make a statement about a matter relevant to the case. As such, “To request that defendant not continue the narrative about her childhood, or delve into her living situation does not abridge defendant’s right to make a statement about a matter relevant to this case before the Grand Jury.” The court distinguished between a fair opportunity to present one’s version of events and unfettered license to introduce irrelevant testimony. The court emphasized that the focus should be on “relevant and competent evidence.”