84 N.Y.2d 1 (1994)

A valid statement of readiness for trial requires the People to be actually ready to proceed at the time the statement is made, and readiness is not established where the People’s own conduct has made it impossible for the defendant to be arraigned within the statutory speedy trial period.

Summary

Crystal England was arrested on a felony complaint on June 24, 1992. Six months later, on December 24, 1992, the Grand Jury handed up an indictment, and the People filed a notice of readiness for trial. England moved to dismiss the indictment, arguing that the People were not ready for trial within the six-month statutory period under CPL 30.30. The County Court granted the motion, and the Appellate Division affirmed. The Court of Appeals affirmed, holding that the People’s delay in securing an indictment, making arraignment impossible within the statutory period, rendered their statement of readiness illusory.

Facts

On June 24, 1992, Crystal England was arrested on a felony complaint. She was arraigned in Town Court and released under supervision. On December 24, 1992, six months after the initial complaint, the Grand Jury issued an indictment. The People filed a notice of readiness for trial along with the indictment on the same day. England had not yet been arraigned on the indictment as of December 24th.

Procedural History

England moved to dismiss the indictment for failure to comply with CPL 30.30. The County Court granted the motion. The Appellate Division affirmed. The New York Court of Appeals granted the People leave to appeal.

Issue(s)

Whether the People can validly declare readiness for trial when, as a result of their own delay in obtaining an indictment, the defendant cannot be arraigned and thus trial cannot commence within the statutory speedy trial period.

Holding

No, because the People’s statement of readiness was meaningless when arraignment within the statutory period was impossible due to the People’s delay in securing an indictment. A valid declaration of readiness requires actual readiness, not just a pro forma announcement.

Court’s Reasoning

CPL 30.30 requires dismissal of a felony indictment if the People are not ready for trial within six months of the commencement of the criminal action. The statutory period began with the filing of the felony complaint on June 24, 1992, and expired on December 24, 1992.

The Court emphasized that “trial readiness in CPL 30.30 means both a communication of readiness by the People on the record and an indication of present readiness.” People v. Kendzia, 64 N.Y.2d 331, 337. The inquiry is whether the People have done all that is required of them to bring the case to a point where it may be tried. The Court distinguished delays caused by court congestion, which do not affect the People’s readiness, from delays caused by the People’s own inaction.

The Court reasoned that because a defendant cannot be brought to trial before arraignment (CPL 1.20[9]), the People’s failure to secure an indictment in a timely manner, thereby preventing arraignment within the statutory period, rendered their statement of readiness meaningless. “Where the trial court and Appellate Division have found the relevant period to be entirely chargeable to the unexplained laxity of the People, the announcement of trial readiness before defendant was even brought before the court can only be an empty declaration, insufficient to satisfy CPL 30.30.”

The dissent argued that the majority’s ruling effectively shortens the six-month period provided by CPL 30.30, requiring the People to ensure not only that they are ready for trial but also that the defendant can be arraigned within that period. The dissent contended that the People had performed all the tasks required of them within the 183 days and that the delay in arraignment was the court’s responsibility. The dissent viewed the majority’s decision as improperly blending the analyses for pre-readiness and post-readiness delay.