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People v. Brown

Appellate Division of the Supreme Court of New York, Second Department
May 8, 1995
215 A.D.2d 492 (N.Y. App. Div. 1995)

Opinion

May 8, 1995


Appeal from the Supreme Court, Queens County (Rotker, J.).

Ordered that the judgment is affirmed.

"Before a defense witness may be cross-examined regarding his or her failure to provide law enforcement authorities with exculpatory information attested to at trial, certain foundational requirements must be met" (People v Pittman, 187 A.D.2d 679; see, People v Dawson, 50 N.Y.2d 311, 321, n 4). The prosecutor in this case failed to comply with the foundational requirements set forth by the Court of Appeals in People v Dawson (supra) prior to cross-examining the defense witness. However, the error was harmless since there is no significant probability that the jury would have acquitted the defendant had the error not occurred (see, People v Ayala, 75 N.Y.2d 422, 431; People v Crimmins, 36 N.Y.2d 230, 241-242).

The defendant's remaining contentions are either unpreserved for appellate review (see, CPL 470.05) or without merit. Miller, J.P., Pizzuto, Joy and Krausman, JJ., concur.


Summaries of

People v. Brown

Appellate Division of the Supreme Court of New York, Second Department
May 8, 1995
215 A.D.2d 492 (N.Y. App. Div. 1995)
Case details for

People v. Brown

Case Details

Full title:THE PEOPLE OF THE STATE OF NEW YORK, Respondent, v. CECIL BROWN, Appellant

Court:Appellate Division of the Supreme Court of New York, Second Department

Date published: May 8, 1995

Citations

215 A.D.2d 492 (N.Y. App. Div. 1995)
627 N.Y.S.2d 564

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