New York Law Review

Tag: People v. Lancaster

  • People v. Lancaster, 85 N.Y.2d 203 (1995): Scope of Defendant’s Testimony Before Grand Jury

    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)

    1. 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

    1. 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.”

  • People v. Lancaster, 69 N.Y.2d 20 (1986): Duty to Present Evidence of Mental Disease or Defect to Grand Jury

    People v. Lancaster, 69 N.Y.2d 20 (1986)

    The prosecution has no obligation to present evidence of a defendant’s psychiatric history to the grand jury to support a potential defense of mental disease or defect, nor is it required to instruct the grand jury on such a defense.

    Summary

    The New York Court of Appeals held that prosecutors are not required to present evidence of a defendant’s psychiatric history to a grand jury, even if it could support a defense of mental disease or defect. Peter Lancaster, a psychiatric patient, was indicted for attempted murder and assault after attacking another patient. Lancaster argued the prosecution should have presented his psychiatric history to the grand jury, especially since he was incompetent to testify himself. The Court of Appeals disagreed, reasoning that the defense of mental disease or defect is a matter for the petit jury, not the grand jury, and that mandating such disclosure would improperly allow the grand jury to circumvent statutory commitment procedures for those found not responsible due to mental illness.

    Facts

    Peter Lancaster, a patient at Hutchings Psychiatric Center under a CPL article 330 commitment, allegedly attacked another patient. He was initially charged with misdemeanor assault. The People notified Lancaster that they would present the case to the Grand Jury. Lancaster’s counsel informed the prosecutor that Lancaster was incoherent and assaultive and unable to intelligently exercise his right to appear before the Grand Jury. The People presented testimony from the victim and facility employees and patients to the Grand Jury but did not present any evidence of Lancaster’s psychiatric history or mental condition at the time of the offense. The People instructed the Grand Jury on the presumption of sanity and the defense of mental disease or defect. Lancaster was indicted for attempted murder, second-degree assault, and third-degree assault.

    Procedural History

    The trial court, based on psychiatric reports, found Lancaster incompetent to stand trial and committed him to a psychiatric facility. After being deemed competent, Lancaster moved to dismiss the indictment, arguing the People wrongfully withheld his psychiatric history from the grand jury, preventing him from presenting an insanity defense or negating the intent element of the charged crimes. The trial court dismissed the attempted murder and second-degree assault counts for insufficient evidence. The Appellate Division reinstated those counts, holding the evidence sufficient and ruling the People were justified in relying on the presumption of sanity. The Court of Appeals granted leave to appeal.

    Issue(s)

    1. Whether the People have a duty to present evidence of a defendant’s psychiatric history to the grand jury when considering a potential defense of mental disease or defect.
    2. Whether an indictment should be dismissed because the defendant was legally incompetent during the grand jury proceedings, precluding him from exercising his right to testify.

    Holding

    1. No, because the defense of mental disease or defect is a matter for the petit jury, and the People are justified in relying on the presumption of sanity.
    2. No, because CPL 730.40(3) authorizes presentation of a case to the grand jury while a defendant is under a temporary order of observation and provides that the Grand Jury need not hear the defendant as it ordinarily must pursuant to CPL 190.50.

    Court’s Reasoning

    The Court of Appeals reasoned that while the grand jury serves to protect individuals from needless prosecutions, the People have wide discretion in presenting their case and are not obligated to search for or present all evidence favorable to the accused. Citing People v. Valles, the court clarified that the prosecutor needs to instruct the Grand Jury only as to those complete defenses that have the potential for eliminating a needless or unfounded prosecution. The defense of mental disease or defect, although potentially a complete defense, does not have the potential for eliminating a needless or unfounded prosecution because a finding of guilt must be made before the defense can be considered. The court emphasized that a successful assertion of the defense triggers mandatory commitment procedures under CPL 330.10(2) and 330.20, reflecting society’s interest in assessing the defendant’s ongoing threat to himself or others. Allowing the grand jury to dismiss charges based on a potential mental disease or defect defense would circumvent these procedures. The court also stated, “[I]nasmuch as it is the proper purpose of an indictment to bring a defendant to trial on a prima facie case, which, if unexplained, would warrant a conviction, the People are justified in relying on the presumption of sanity.” The court found no merit in the argument that the evidence should have been presented to negate intent, as the prosecutor is under no duty to instruct the grand jury as to mitigating defenses. Finally, the Court upheld the Appellate Division’s ruling that CPL 730.40(3) allows for presentation of a case to the grand jury even when a defendant is committed under a temporary order of observation.