14 N.Y.3d 61 (2010)
The “exceptional circumstances” exclusion to the speedy trial rule requires the prosecution to demonstrate that, for practical reasons beyond their control, they could not proceed with a legally viable prosecution, and it does not apply where the delay is a result of prosecutorial inaction.
Summary
Price was charged with attempted disseminating indecent material to minors. After an intermediate appellate court decision made such a prosecution legally untenable, the prosecution paused the case, but did not dismiss it or notify the defendant. After the New York Court of Appeals reversed that intermediate decision, the prosecution moved forward, more than six months after the initial charge. The Court of Appeals held that the time between the intermediate court’s decision and its reversal did not constitute “exceptional circumstances” excusing the delay under CPL 30.30(4)(g), emphasizing the need to discourage prosecutorial inaction and ensure defendants are informed about the status of their cases.
Facts
Defendant Price was arraigned on February 2, 2006, on a felony complaint for attempted disseminating indecent material to minors. The charge stemmed from explicit internet conversations with an undercover officer posing as a 14-year-old, but no sexual images were transmitted.
Procedural History
The Second Department held in People v. Kozlow that a conviction for disseminating indecent material requires the transmission of sexual images. The District Attorney, bound by this precedent, determined that Price could not be indicted, but left the criminal complaint pending. The New York Court of Appeals reversed Kozlow, holding that no images were required for a conviction. The People then indicted Price, more than six months after his initial arraignment. The Supreme Court granted Price’s motion to dismiss based on speedy trial grounds. The Appellate Division affirmed. The Court of Appeals granted leave to appeal.
Issue(s)
Whether the interval between an intermediate appellate court decision holding a prosecution legally untenable and a Court of Appeals decision reversing that holding constitutes “exceptional circumstances” under CPL 30.30(4)(g), excusing the prosecution’s delay in bringing the case to trial.
Holding
No, because the delay was the result of prosecutorial inaction, as the People failed to either withdraw the complaint or seek a continuance, and this inaction does not constitute exceptional circumstances under CPL 30.30(4)(g).
Court’s Reasoning
The Court of Appeals emphasized that CPL 30.30 aims to prevent prosecutorial inaction. While there is no precise definition of “exceptional circumstances,” the term is limited by the legislative intent to discourage inaction. The exclusion applies only when the People, for practical reasons beyond their control, cannot proceed with a legally viable prosecution. The Court highlighted that the prosecutor could have sought a continuance from the court, ensuring judicial oversight and keeping the defendant informed. Here, the People concede there was no legal basis to proceed after the intermediate appellate court’s decision. The Court stated, “[l]egal rulings are routine events in criminal trials. The fact that a particular ruling may be erroneous does not by itself transform that ruling into an ‘exceptional circumstance.’” While the People were not in control of the appellate court’s erroneous decision, they did have control over the criminal complaint and allowed it to stand, despite the apparent legal impediment. The Court concluded that applying the exclusion here would allow criminal complaints to pend indefinitely based on the mere possibility of a change in the law. The Court acknowledged the potential for unfortunate results where a defendant may benefit from an erroneous appellate decision, but reiterated that speedy trial cases often transcend the specifics of a particular defendant’s guilt, and exist to protect the public interest.