People v. Williamson, 51 N.Y.2d 762 (1980)

A defendant is not entitled to disclosure of an informant’s identity unless they make an extremely strong showing of relevance, especially when the informant’s information is marginal.

Summary

This case concerns the extent to which a criminal defendant is entitled to the disclosure of an informant’s identity. The Court of Appeals held that because the informant’s information identifying the defendant was marginal, and the defendant failed to properly preserve objections, there was no error in denying disclosure. The Court further addressed and dismissed the defendant’s arguments regarding merger and the jury charge on motive. The decision underscores the high bar for compelling informant disclosure and the importance of preserving legal arguments at trial.

Facts

An informant observed the defendant walking with a child and provided the defendant’s name and address to the police. The defendant was subsequently charged with kidnapping. Prior to trial, the defendant sought disclosure of the informant’s identity, but the request was denied. At a Darden hearing (a proceeding to determine the reliability of an informant), the defendant submitted questions to be asked of the informant, potentially seeking exculpatory information. The Trial Judge’s memorandum after the Darden hearing did not explicitly refer to those questions.

Procedural History

The defendant was convicted of kidnapping at trial. The defendant appealed, arguing that he was entitled to disclosure of the informant’s identity, that the kidnapping charge should have merged with another crime, and that the jury charge regarding motive was erroneous. The Appellate Division affirmed the conviction. The defendant then appealed to the New York Court of Appeals.

Issue(s)

1. Whether the defendant was entitled to disclosure of the informant’s identity, given the marginal nature of the information provided and the lack of a strong showing of relevance.

2. Whether the trial court erred in denying the defendant’s motion to dismiss based on merger.

3. Whether the trial court erred in its charge to the jury regarding the necessity of proving motive for the abduction.

Holding

1. No, because the informant’s information was marginal, and the defendant failed to make an extremely strong showing of relevance or properly object to the lack of explicit reference to his questions in the Darden hearing memorandum.

2. No, because no crime other than kidnapping was charged.

3. No, because although a charge that the jury could consider motive on the issues of intent and knowledge would not have been improper if requested, the defendant’s attorney simply excepted to the charge as given and made no such request, thus failing to preserve the issue for review.

Court’s Reasoning

The Court reasoned that the defendant was not entitled to disclosure of the informant’s identity because the information provided—observing the defendant walking with the child and providing his name and address—was of a marginal nature. The Court cited People v. Goggins, 34 N.Y.2d 163, 170, stating that disclosure is not required “absent an extremely strong showing of relevance.” The Court also emphasized that the defendant did not move for disclosure or object to the Trial Judge’s memorandum, failing to preserve the issue for appeal. Regarding the merger argument, the Court noted that since no other crime was charged besides kidnapping, the motion to dismiss based on merger was properly denied, citing People v. Cassidy, 40 N.Y.2d 763. Finally, the Court addressed the jury charge on motive, stating that while it would not have been improper to charge that the jury could consider the defendant’s motive on the issues of his intent and knowledge that restraint of the child was unlawful, the defendant’s attorney did not request such a charge and thus did not preserve the issue for review, citing People v. Sangamino, 258 N.Y. 85 and People v. Seppi, 221 N.Y. 62. The Court’s decision underscores the importance of preserving objections and adhering to established legal standards regarding informant disclosure.