People v. Matthews, 88 N.Y.2d 1047 (1996)
A defendant must specifically identify legal or factual impediments to the People’s reliance on statutory exclusions under CPL 30.30 to preserve a challenge to a speedy trial claim for appellate review.
Summary
Matthews was indicted on August 20, 1991, but not arraigned until April 2, 1992, when the People declared readiness. He moved to dismiss the indictment on speedy trial grounds, arguing the delay was chargeable to the People. The People argued a 35-day medical quarantine of Matthews was excludable under CPL 30.30 (4)(c) and (g). The Supreme Court denied the motion, and the Appellate Division affirmed. The Court of Appeals affirmed, holding that Matthews failed to preserve his argument that the People needed to establish a causal relationship between his quarantine and their delay in declaring readiness. The Court emphasized the importance of providing the lower court with an opportunity to address and remedy any potential errors.
Facts
Matthews was indicted on August 20, 1991, for unauthorized use of a vehicle and criminal possession of stolen property.
He was arraigned on April 2, 1992, at which time the People declared their readiness for trial.
During the period between February 27, 1992, and April 2, 1992, Matthews was under medical quarantine.
Procedural History
The defendant moved to dismiss the indictment based on a violation of speedy trial rules.
The Supreme Court denied the motion.
The Appellate Division affirmed the Supreme Court’s decision, citing CPL 30.30 (4)(c) and (g).
The Court of Appeals affirmed the Appellate Division’s order.
Issue(s)
Whether a defendant preserves a challenge to the People’s reliance on CPL 30.30 (4)(c) and (g) exclusions by merely arguing general causation principles, without specifically arguing that the exclusions are unavailable absent a causal link between the defendant’s condition and the People’s delayed readiness.
Holding
No, because once the People identify statutory exclusions, the defendant must specifically identify legal or factual impediments to the use of those exclusions to preserve the issue for appellate review.
Court’s Reasoning
The Court of Appeals held that to preserve a speedy trial claim for appellate review, a defendant must do more than simply allege a failure to declare readiness within the statutory period. According to the court, once the People identify the statutory exclusions they intend to rely on, the defendant must specifically identify any legal or factual impediments to the use of those exclusions. The Court stated that “[t]he purpose of adhering to strict rules of preservation in this context is to provide the court with an ‘opportunity to remedy the problem and thereby avert reversible error.’” The Court found that Matthews’ argument focused on general causation principles and did not specifically argue that the medical quarantine exclusions required a causal link between the quarantine and the People’s delay. Because he did not raise this specific argument before the motion court, he failed to preserve the issue for appellate review. The Court referenced People v. Luperon, stating that the defendant must alert the court to the claim that lack of causation was an impediment to the People’s reliance on CPL 30.30(4)(c) and (g).