In re Randy K., 77 N.Y.2d 398 (1991)

A juvenile’s failure to appear in court, resulting in a bench warrant, does not automatically relieve the presentment agency of its obligation to adhere to the speedy hearing requirements outlined in the Family Court Act, specifically the need to demonstrate good cause or special circumstances for adjournments.

Summary

This case addresses whether a juvenile’s failure to appear at a scheduled fact-finding hearing automatically waives the statutory requirements for speedy hearings under the Family Court Act § 340.1. The Court of Appeals held that the presentment agency was still obligated to seek adjournments based on good cause or special circumstances, even after a bench warrant was issued for the juvenile’s arrest. The court reasoned that creating an exception for failure to appear would undermine the purpose of ensuring swift and certain determinations in juvenile delinquency proceedings and would improperly shift responsibility for monitoring the case away from the court and the presentment agency.

Facts

A petition was filed against Randy K. alleging acts that would constitute robbery if committed by an adult. Randy failed to appear at the initial court date, and a bench warrant was issued. He was brought in on the warrant approximately 150 days later. He failed to appear again for a fact-finding hearing which was also set and a second bench warrant issued. He was brought in on the second warrant months later. The Family Court denied Randy’s motion to dismiss based on a violation of speedy hearing rights, arguing his absence was voluntary. The Appellate Division reversed.

Procedural History

The Family Court denied the respondent’s motion to dismiss the petition. The Appellate Division reversed the Family Court’s decision and dismissed the petition. The Court of Appeals granted leave to appeal.

Issue(s)

Whether a juvenile’s failure to appear at a scheduled fact-finding hearing and the subsequent issuance of a bench warrant automatically relieve the presentment agency from complying with the statutory requirements of Family Court Act § 340.1 regarding adjournments for good cause or special circumstances.

Holding

No, because the Family Court Act § 340.1 mandates that adjournments of fact-finding hearings require a showing of good cause or special circumstances on the record, and there is no exception for situations where the juvenile fails to appear and a bench warrant is issued.

Court’s Reasoning

The Court of Appeals reasoned that Family Court Act § 340.1 provides specific time limitations for fact-finding hearings, distinct from the general speedy trial provisions for adult prosecutions. The statute mandates that the court must order adjournments and make findings on the record regarding good cause or special circumstances. The court emphasized that “[t]he statute contains no exception from these mandates when the juvenile has failed to appear and is being sought under a bench warrant.” Creating an automatic exception for failure to appear would undermine the goals of swift and certain determinations and proper supervision of juveniles. The Court stated, “Providing for an automatic retroactive adjournment of unlimited duration based solely upon a failure of a juvenile to appear for a hearing and the issuance of a bench warrant would in no way advance the aims of ensuring a swift and certain determination of the proceeding and supervision of the juvenile.” The court rejected the argument that the agency’s failure should be excused because the motion would have been granted, emphasizing the mandatory nature of the statutory protections. The Court further noted the difference between CPL 30.30, which focuses on prosecutorial delay, and Family Court Act § 340.1, which is a true speedy hearing rule, and stated, “[t]he two statutes have ‘very different language, history and purposes.’”