Conviction reversed and new trial ordered: trial court required the People to give race-neutral reasons for peremptory challenges — implicitly finding a prima facie Batson case — then erroneously denied the challenge at step 1 without proceeding to pretext analysis at step 3.
Appellate Division affirms dismissal of weapons indictment after finding the DA’s Certificate of Compliance was invalid — failure to disclose police memo books and property vouchers constituted a lack of due diligence under CPL 245, triggering a speedy-trial violation under CPL 30.30.
The Appellate Division, Second Department sustained a habeas writ for a defendant held more than 90 days without a valid certificate of compliance, finding the People’s supplemental CoC deficient because 60-plus automatic discovery items—including mandatory impeachment materials—remained outstanding at the time of filing.